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Germany Post-Quantum Cryptography Regulation: What BSI TR-02102 Actually Requires

BSI TR-02102-1 version 2026-01 names migration dates: classical-only key agreement ends 2031, high-protection systems by 2030, signatures by 2035. Here is who is in scope under BSIG and what to do first.

Nagib Aouini··11 min read

Germany Post-Quantum Cryptography Regulation: What BSI TR-02102 Actually Requires


Germany does not hide its post-quantum position behind a single statute that names ML-KEM. The Federal Office for Information Security (BSI) publishes Technical Guideline TR-02102-1 as the national reference for cryptographic mechanisms and key lengths, and the January 2026 revision is the first version that puts calendar dates on the retirement of classical-only key agreement. Those dates become an operational obligation for a large set of organisations through the revised BSI Act (BSIG), which already requires "concepts and processes for the use of cryptographic procedures," and through BSI minimum standards that bind the federal administration more tightly than the Technical Guideline itself.

This guide covers four things: what the BSI actually said in TR-02102-1 version 2026-01, who sits in scope under the BSIG and related federal rules, the migration timeline those documents now set, and the practical first steps that matter before any algorithm swap: cryptographic inventory, HSM/KMS readiness, and hybrid PQC deployment.


Table of Contents

  1. What the Regulator Said
  2. Who Is in Scope
  3. The Timeline
  4. Practical First Steps
  5. The Technical Checklist
  6. How This Maps to DuoKey Cockpit
  7. FAQ

What the Regulator Said

On 23 January 2026 the BSI published TR-02102-1 version 2026-01, Cryptographic Mechanisms: Recommendations and Key Lengths. The guideline remains a Technical Guideline, not a statute. It is still the document German auditors, federal IT projects and KRITIS-adjacent operators treat as the working definition of acceptable cryptography.

Three statements in the 2026-01 text matter more than the rest:

  1. Store-now-decrypt-later is treated as a present risk. The guideline states that classical asymmetric key agreement and signature mechanisms lose security once sufficiently large quantum computers exist, and that intercepted ciphertext with a long confidentiality requirement is already a relevant threat.
  2. Hybrid key agreement is the recommended transition mode. Quantum-safe key encapsulation (KEM) should be combined with a classical mechanism so the session remains secure if either half holds. The BSI lists FrodoKEM, Classic McEliece and ML-KEM (ML-KEM-768 and ML-KEM-1024 for the security levels targeted in the guideline) as quantum-safe key-agreement options. Hybrid here means classical plus quantum-safe, not a mandatory dual-PQC stack.
  3. Classical-only key agreement has an end date. Sole use of classic key agreement is recommended only until the end of 2031. Applications with very high protection requirements should complete the move to quantum-safe mechanisms by the end of 2030. Classical signature mechanisms follow a longer horizon aligned to the European Commission's roadmap: migration to quantum-safe signatures by 2035 at the latest.

Protocol detail for TLS, IPsec and SSH lives in the companion guidelines TR-02102-2, TR-02102-3 and TR-02102-4. If you terminate TLS or IPsec in Germany, those companions are part of the same BSI package, not optional reading.


Who Is in Scope

TR-02102 itself is recommendatory. Scope comes from how other German instruments use it.

LayerWho it bindsHow cryptography shows up
BSIG §30 (post NIS2 transposition)Entities of particular importance and important entities under the revised BSI ActExplicit duty to maintain concepts and processes for the use of cryptographic procedures, alongside risk management, incident handling and supply-chain controls
Federal administrationFederal authorities and systems covered by BSI minimum standards under BSIGMinimum standards (for example TLS) are binding for the federal administration and point into the TR-02102 series for technical content
KRITIS / critical operatorsOperators previously under the KRITIS regime and the wider set captured by NIS2UmsuCGAssessed against BSIG risk-management measures; BSI Technical Guidelines are the practical technical reference for "state of the art"
DORA / financial entitiesEU financial entities operating in GermanyDORA's RTS still set the detailed encryption and key-management bar for those entities; see our DORA checklist. TR-02102 remains the German national algorithm reference underneath that EU layer
GDPR / BDSGControllers and processors of personal dataArticle 32-style "appropriate" security, interpreted against current risk and recognised technical guidance, including BSI publications

Germany's NIS2 implementation act (NIS2UmsuCG) has applied since December 2025 and rewrote the BSIG around the EU categories of particularly important and important entities. Cryptography is no longer an implied control inside a general ISMS obligation. Section 30 names it. That does not turn every TR-02102 table into statute, but it does mean a regulated entity that cannot show a cryptography concept, inventory and migration path has a direct statutory gap, not just a best-practice gap.

If you sell into the federal administration, treat BSI minimum standards plus TR-02102 as the floor your product cryptography has to clear. If you are an important or particularly important entity under BSIG, treat TR-02102's migration dates as the concrete content of the cryptography concepts §30 already requires you to maintain.


The Timeline

ByMilestone (BSI TR-02102-1 v2026-01 / EU roadmap)
End of 2030Complete migration to quantum-safe mechanisms for applications with very high protection requirements
End of 2031End of recommended sole use of classical key agreement; classical methods beyond this date only in combination with quantum-safe mechanisms
2035Migration to quantum-safe signature mechanisms, following the European Commission roadmap that TR-02102 explicitly adopts

Compared with the UK NCSC timeline (discovery by 2028, priority migration by 2031, full migration by 2035), Germany front-loads the key-agreement problem and is more explicit that classical-only KEMs should not still be running after 2031. Signatures get the longer runway both jurisdictions now share.

There is no separate German "PQC Act" with a single compliance filing date. The calendar lives in TR-02102. Enforcement pressure arrives through BSIG assessments, federal procurement and minimum standards, and sector supervision that already asks whether your cryptography concept is current.


Practical First Steps

1. Cryptographic inventory

BSIG §30's "concepts and processes for the use of cryptographic procedures" is empty without a map of what you actually run. Build an inventory that covers:

  • Algorithms and parameter sets for key establishment, signatures and bulk encryption
  • Certificates and PKI chains, including intermediate and code-signing material
  • Protocols (TLS, IPsec, SSH, VPN) and where they terminate
  • Keys held in HSMs, KMS services, application vaults and cloud provider-managed stores
  • Data classes with multi-year confidentiality requirements (the store-now-decrypt-later set)

A CycloneDX Cryptography Bill of Materials (CBOM) is the practical artefact format. Our CBOM guide covers generating one from filesystem, source and domain scans. Prioritise systems that still use classical-only key agreement on paths carrying long-lived confidential data; those are the 2030/2031 problem, not a 2035 problem.

2. HSM and KMS readiness

Algorithm choice is only half of what BSI assessors and BSIG reviewers look for. Key lifecycle (generation, storage, rotation, backup, destruction) has to survive a change of algorithm. Before you pilot hybrid PQC:

  • Confirm whether each HSM or KMS in scope can issue, store and use the key types you will need (ML-KEM / ML-DSA material, hybrid key derivation, larger certificate objects)
  • Separate root-of-trust material from application keys so a PQC cutover does not force a rebuild of every dependent system
  • Document who can approve algorithm changes in the cryptography concept §30 already expects you to maintain
  • Identify vendor-managed keys you do not control; those become contractual migration dependencies, not local configuration tasks

If a device or cloud KMS cannot support hybrid or PQC key establishment, put it on the replacement or decommission list now. Waiting until 2030 to discover that fact is how programmes miss the high-protection deadline.

3. Hybrid PQC deployment

TR-02102's transition recommendation is hybrid key agreement: classical plus a quantum-safe KEM, combined through a suitable KDF so the result stays secure if either component holds. That matches the hybrid groups already shipping in common TLS and IPsec stacks (for example X25519MLKEM768-style combinations).

Start on internet- and partner-facing termination points where harvest-now-decrypt-later exposure is highest:

  • Edge TLS on load balancers and ADC platforms (F5 BIG-IP guide)
  • Site-to-site and remote-access IPsec (FortiGate guide)
  • Internal service mesh and API gateways once the edge pattern is proven

Keep the hybrid step transitional in documentation as well as configuration. TR-02102's logic is that classical-only agreement ends; hybrid is the bridge, not the permanent resting state for every system. Signature migration (ML-DSA, SLH-DSA, or stateful hash-based schemes where appropriate) can follow on the longer 2035 track, but firmware and code-signing paths with long device lifetimes should not wait until the last year.


The Technical Checklist

  • You have confirmed whether you are an important or particularly important entity under the revised BSIG, and whether any federal minimum standards apply to your systems
  • A cryptography concept exists that names approved algorithms, key lengths, key lifecycle and a PQC migration path, satisfying BSIG §30's cryptography-process requirement in substance
  • A cryptographic inventory (ideally CBOM) covers key agreement, signatures, certificates, TLS/IPsec/SSH termination points and key stores
  • Systems with very high protection requirements and long-lived confidentiality needs are prioritised for quantum-safe key agreement by end of 2030
  • Classical-only key agreement has a documented retirement plan no later than end of 2031
  • Hybrid deployments combine a classical mechanism with a BSI-listed quantum-safe KEM (ML-KEM-768/1024, FrodoKEM or Classic McEliece as appropriate), not classical-only "PQC-ready" marketing claims
  • HSM/KMS platforms in scope can hold and operate the required key types, or are scheduled for replacement
  • Signature and PKI migration is planned against the 2035 horizon, with earlier action for firmware and long-lived code-signing
  • If you are also DORA-regulated, RTS encryption and key-management obligations are mapped alongside TR-02102 rather than treated as a substitute for it

How This Maps to DuoKey Cockpit

The inventory behind BSIG §30 and TR-02102's migration dates is exactly what a CBOM captures: algorithms, certificates and keys in a machine-readable form you can re-scan instead of rebuilding for each audit. Our CBOM guide covers generation and the get_qrs_score / get_vulnerable_assets tools for tracking classical-only key agreement that still sits past your 2030/2031 cut lines.

For hybrid deployment on common German enterprise edge gear, the F5 and FortiGate guides cover ML-KEM hybrid profiles, including the MCP tools that turn a prioritised inventory into configuration changes. Key lifecycle that has to survive algorithm change maps to DuoKey's KMS and MPC-based vault controls, so the cryptography concept you maintain for §30 is enforced configuration rather than a PDF that ages poorly.


FAQ

Q: Is TR-02102 legally binding?

Not as a standalone statute. It is a BSI Technical Guideline. It becomes the practical bar through BSIG §30's cryptography-process duty, through binding BSI minimum standards for the federal administration, and through assessments that treat BSI guidance as state of the art. Ignoring the 2030/2031/2035 dates while claiming a current cryptography concept is a weak position.

Q: Does BSI require ML-KEM combined with FrodoKEM?

No. TR-02102 recommends hybrid use of a classical mechanism with a quantum-safe KEM. FrodoKEM, Classic McEliece and ML-KEM are listed as quantum-safe options. Dual quantum-safe stacking is not what the guideline means by hybrid.

Q: How does this relate to NIS2?

Germany's NIS2 transposition rewrote the BSIG and expanded who must implement the §30 risk-management measures, including cryptography concepts. The EU implementing regulation for certain digital entities still applies where it is more specific; see our NIS2 crypto-agility guide. TR-02102 fills in the German algorithm and migration detail NIS2 does not name.

Q: We are a bank in Frankfurt. Do we follow BSI or DORA?

Both. DORA's RTS set detailed EU financial-sector encryption and key-management rules. TR-02102 remains the national cryptographic reference German supervisors and auditors recognise for algorithm choice and migration timing. Design once against the stricter reading of both.


Conclusion

Germany's PQC posture is unusually concrete for a country without a single named-algorithm PQC statute. BSI TR-02102-1 version 2026-01 sets the dates: high-protection quantum-safe key agreement by 2030, end of classical-only key agreement by 2031, signatures by 2035, with hybrid classical-plus-PQC as the recommended bridge. BSIG §30 and federal minimum standards are what turn that guidance into an expectation you can be assessed against. Build the inventory, prove your HSM/KMS estate can change algorithms, and deploy hybrid on the paths that already carry long-lived confidential data.


References

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Written by

Nagib Aouini

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