Matrix CR Studio

Financial services in the EU

DORA already asks for a plan to change your cryptography.

EU financial entities have a binding rule about cryptography that ages. DORA’s technical standard requires an encryption policy that provides for replacing the cryptography when attacks on it improve. A quantum computer that breaks today’s public-key algorithms is that kind of improvement.

DORA has applied since 17 January 2025 (Article 64). DORA on EUR-Lex

What the rules say

Four sentences from the technical standard.

Regulation (EU) 2024/1774, Article 6(4)

“provisions for updating or changing, where necessary, the cryptographic technology on the basis of developments in cryptanalysis”

Your encryption policy has to say how you will replace cryptography that stops being safe.

Read the source
Regulation (EU) 2024/1774, Article 6(5)

“a requirement to record the adoption of mitigation and monitoring measures adopted in accordance with paragraphs 3 and 4 and to provide a reasoned explanation for doing so”

Where you cannot update yet, you record what you did instead, and why.

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Regulation (EU) 2024/1774, Article 7(1)

“managing cryptographic keys through their whole lifecycle, including generating, renewing, storing, backing up, archiving, retrieving, transmitting, retiring, revoking, and destroying those cryptographic keys”

Retiring a key is part of the policy, which is what a migration does to every quantum-vulnerable key.

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Regulation (EU) 2024/1774, Article 7(4)

“a register for all certificates and certificate-storing devices for at least ICT assets supporting critical or important functions”

You need to know where your certificates are before you can replace them.

Read the source

These articles sit in Title II of the standard. Smaller entities listed in DORA Article 16(1), such as small and non-interconnected investment firms, follow its simplified framework in Title III instead.

The standard does not mention quantum computers. The EU’s post-quantum roadmap cites DORA and NIS2 as rules that already require state-of-the-art cryptography, and its FAQ says post-quantum migration is crucial for protecting financial systems. The roadmap and its FAQ

The dates

EU Coordinated Implementation Roadmap.

Issued 23 June 2025. A recommendation to EU Member States, not a law that binds a firm directly. It cites DORA and NIS2 as rules that already require state-of-the-art cryptography.

31 December 2026National transition plans and first pilots
31 December 2030High-risk use cases transitioned
31 December 2035Medium-risk use cases transitioned

What an assessment gives you

Each part, against what it serves.

Article 7(4), the certificate register

The inventory: the cryptography found in the code and dependency manifests you give us, each finding with the file and line where it was seen. It is a starting point for the register, not the register itself: certificates on devices we cannot scan come from you, and are marked as such.

Article 6(4), updating on developments in cryptanalysis

The exposure ranking and the migration plan: which public-key uses a quantum computer breaks, in what order to replace them given how long their data must stay secret, and with what.

Article 6(5), the record and the reasoned explanation

The evidence file: the inventory, the ranking and the plan as linked, signed records, with the assumptions behind the ranking sealed in. The reasoned explanation is yours to write; the file gives it something an auditor can check.

What this is not

Next

See what the deliverable looks like.

The sample is a made-up Spanish bank run through the real method, with each finding cross-referenced to the articles above.

The assessmentA sample deliverable

Quotations read from EUR-Lex on 21 September 2026.