Business case and scope
- CISO
- A · Accountable
- Inventory owner
- R · Responsible
- Solutions architect
- C · Consulted
- Technical PM
- C · Consulted
- Engineers
- I · Informed
- System owners
- C · Consulted
- Procurement
- I · Informed
A living inventory of where RSA and elliptic curve cryptography are used across your code, certificates, devices and suppliers, found and classified by AI, confirmed by the people who own each system, and turned into a migration plan your board approves. The AI never changes a key, a certificate or a line of code.
At a glance
An illustrative scenario. The numbers are typical examples, not a client case study. The cloud services and UK rules were checked on 9 November 2026.
Almost every system you run relies on public-key cryptography: TLS on every website and API, VPNs, code signing, single sign-on tokens, payment links, device certificates, encrypted backups. Most of it is RSA or elliptic curve cryptography, and a large enough quantum computer would break both. Data recorded today could be decrypted later, so information that must stay confidential for ten years or more is already exposed in principle.
The NCSC has set the UK's timeline: by 2028, define your migration goals, complete discovery and have an initial plan; by 2031, finish the highest-priority migrations; by 2035, migrate everything. The first step is the hardest. Cryptography hides in libraries pulled in by other libraries, in configuration files, in certificates nobody remembers issuing, in network appliances, in building and plant equipment, and inside suppliers' products and services. A spreadsheet put together by asking each team rarely survives its first audit.
AI can do much of the finding and sorting: reading code and configuration, listing certificates and keys, reading suppliers' product documents and security statements, and classifying what it finds with the evidence attached. But a wrong finding can send a team chasing nothing, and a missed one can leave a critical system on the old algorithms in 2035. So people confirm every finding and set every priority, and no change to a key, certificate or system is ever made by the AI.
Agree these, and measure the baseline, before anything is built. Example targets are typical, not promises.
The share of in-scope systems whose cryptography has been discovered and confirmed by the system owner.
ExampleEvery high-priority system before the plan is approved
In a weekly sample, the share of AI findings that owners confirm as correct. Low precision wastes owners' time and they stop reading.
ExampleAbove 90%, every rejection reviewed
Systems and devices where the cryptography can't yet be established, often embedded or supplier-run.
ExampleFalling every month, each with an owner and a next step
Critical suppliers with a documented answer on their post-quantum plans and dates.
ExampleAll critical suppliers by the 2028 plan
Systems protecting data that must stay confidential beyond 2035 that still use quantum-vulnerable key exchange.
ExampleKnown, prioritised and falling
Keys, certificates, configuration or code changed by the agents. Checked from the platform's audit logs.
ExampleZero
Cross-sector rules are on the UK regulation map.
Indicative milestones, not law: by 2028 define goals, complete discovery and build an initial plan that covers supplier dependencies and long-lived hardware roots of trust; by 2031 finish the highest-priority migrations; by 2035 complete migration. The NCSC says discovery doesn't need to be a formal asset register, just enough understanding to plan. This design keeps the inventory as light as that allows, but owned and kept current, because the plan will be revised for years.
The NCSC recommends ML-KEM-768 and ML-DSA-65 for most uses, treats hybrid post-quantum and traditional schemes as an interim step, and suits SLH-DSA or carefully managed LMS and XMSS to firmware and software signing. Its TLS guidance lists hybrid key exchange groups such as X25519MLKEM768, asks you to enable a post-quantum key exchange as soon as your software supports it, and doesn't yet recommend post-quantum certificates. The classification rules in the inventory follow these documents, held in the retrieval index so every classification cites them.
For operators of essential services, the inventory supports asset management (A3) and supply chain (A4), including A4.b, which expects suppliers to understand the third-party components in the software they provide. The agents are a new system too: they need their own access control, logging and a place in the CAF self-assessment.
If you're FCA-regulated: the FCA expects firms to build an accurate picture of where and how cryptography is used as a first step, to follow the NCSC milestones without waiting for them, and for senior managers to commit enough time and money. The G7 group, co-chaired by the Bank of England, set a non-binding 2035 planning horizon for the financial sector. Keep the inventory and plan in a form you could show your supervisor.
Security must take account of the state of the art and the risks. For personal data that must stay confidential for many years, harvest-now-decrypt-later is a risk to weigh now, so long-lived personal data is one of the priority factors. The discovery tools also read commit history, which names developers: keep findings to what the plan needs and control who sees them.
The standards the NCSC's recommendations are built on. NIST selected HQC as a backup key encapsulation algorithm in March 2025, and FN-DSA (from Falcon) is still going through standardisation. NIST says it will remove quantum-vulnerable algorithms from its standards by 2035. The inventory records algorithm names exactly, so new standards can be added without reclassifying everything.
Showing AWSAzuresovereign / on-prem services. Switch with the toggle; every diagram and table on this page follows it.
01Sources
02Intake
03Intelligence
04Orchestration
05Systems of record
06People
| Layer | AWS | Azure | Sovereign / on-prem |
|---|---|---|---|
| Read-only collectorsEach collector has one read-only job: list repositories, list certificates, export scan results. They send findings and short code snippets, not whole repositories, unless you choose otherwise. | AWS Lambda with EventBridge Scheduler, inside your network or VPC | Azure Functions, inside your network or VNet | Kubernetes CronJobs, or n8n |
| Code and configuration searchPattern searches find candidate uses fast; the agent reads the surrounding code to work out what is really used, through which library, and for what. | Your code scanning tools, plus the agent reading flagged files through read-only repository access | Your code scanning tools, plus the agent reading flagged files through read-only repository access | Your code scanning tools, plus the agent reading flagged files through read-only repository access |
| Cloud keys and certificatesMetadata only: algorithm, key size, issuer, expiry, where it's used. The collectors' roles can't read or export private keys. | AWS Config, AWS Certificate Manager, AWS KMS and AWS Private CA list APIs | Azure Resource Graph, Azure Key Vault certificate and key listings | Your PKI's and key manager's own APIs, and your HSM's audit exports |
| Reading supplier documentsContracts, product security statements, data sheets and questionnaire answers, with page references kept. | Amazon Textract, or Bedrock Data Automation (processes London requests in eu-west-2; re-check before relying on it) | Azure Content Understanding (includes Document Intelligence) | Open-source parsing (e.g. Docling) plus an open-weight vision model |
| Guidance and document index (retrieval)Holds the NCSC and NIST documents your rules follow, your own crypto policy, and supplier documents. Every classification cites the rule it applied. | Bedrock Knowledge Bases | Foundry IQ, built on Azure AI Search | OpenSearch, or PostgreSQL with pgvector |
| Reasoning and classificationBoth clouds offer a choice of models, including Claude. Many organisations won't send source code outside their estate; open-weight models on your own GPUs make that possible. | Amazon Bedrock | Microsoft Foundry | Open-weight models served with vLLM on your own GPUs |
| Agent runtimeThe original Bedrock Agents closed to new customers on 30 July 2026; new builds use AgentCore. | Amazon Bedrock AgentCore | Foundry Agent Service | An open-source agent framework (e.g. LangGraph) on Kubernetes |
| Inventory storeOne row per use of cryptography, with evidence, classification, owner, confirmation and history. Exportable in the CycloneDX CBOM format, so the record isn't tied to any tool. | Amazon Aurora PostgreSQL | Azure Database for PostgreSQL | PostgreSQL |
| Owner reviewOwners confirm or correct findings where they already work. Any change that follows goes through normal change management. | In your ITSM or GRC tool | In your ITSM or GRC tool | In your ITSM or GRC tool |
| Workflow and eventsNew certificates, repositories and suppliers raise events, so the inventory keeps up without another big project. | AWS Step Functions, EventBridge, SQS | Logic Apps or Durable Functions, Event Grid, Service Bus | Temporal, Apache Kafka or RabbitMQ |
| Post-quantum options on each platform (for the plan, not the AI)Inputs to the migration plan. People decide which to adopt, test them and roll them out through change control. Confirm each against your own regions and versions. | AWS KMS ML-DSA and ML-KEM keys; AWS Private CA ML-DSA certificates; hybrid ML-KEM TLS on the KMS, ACM and Secrets Manager endpoints | ML-KEM and ML-DSA in Windows 11 and Windows Server 2025 (CNG, generally available November 2025); ML-DSA certificates in AD CS (May 2026 update) | Open-source libraries with ML-KEM and ML-DSA (e.g. OpenSSL 3.5) |
| GuardrailsCode comments and supplier documents can carry text aimed at the agent. The real control is that the agents have no write tools. | Bedrock Guardrails | Foundry guardrails (Azure AI Content Safety), including Prompt Shields | Open-source guardrails (e.g. NeMo Guardrails, Llama Guard) |
| Identity, keys, data protectionSeparate read-only identities for each collector and agent, reviewed like privileged accounts. | IAM roles per agent, KMS, Secrets Manager | Entra ID workload identities, Key Vault | Keycloak or your existing Active Directory; OpenBao or HashiCorp Vault; an HSM |
| Monitoring and auditLog every finding, confirmation, correction and priority decision, and every refused tool call. | CloudWatch, CloudTrail | Azure Monitor, Log Analytics | Prometheus, Grafana, OpenTelemetry |
| UK data residencySource code and a map of your weak points are sensitive. Keep them in the UK and restrict who can read the inventory. | eu-west-2 (London) | UK South / UK West | Your own UK data centre, or a UK provider |
On a phone, the table shows the platform you pick. Sovereign / on-prem means open, portable components you can run in your own data centre or with a UK or European provider; IONOS is shown as one example, and others exist. What sovereign cloud means →
Many organisations keep core systems and sensitive data on their own servers. This is how the same design works across both.
Stays on-prem
Code repositories, HSMs, the internal PKI, network appliances and plant equipment stay where they are. Private keys never leave their stores, and the agents never see them.
Uses cloud AI
Classification, the guidance index and the supplier evidence agent can run in a UK cloud region. If source code must not leave your estate, run the discovery agent on your own GPUs with open-weight models and send only classified findings to the cloud.
How they connect
Collectors inside your network send findings outbound over AWS Direct Connect, Azure ExpressRoute or a VPN. No inbound path from the cloud reaches a repository, key store or device.
If the link drops
Discovery pauses and picks up where it left off. The inventory stays readable on-prem, and nothing in production depends on the AI being up.
What each agent may do through its tools, what it may not, and where a person signs off. The limits are enforced by the platform, not the prompt.
Discovery and classification agent
Where a person signs offThe system owner confirms or corrects every finding and sets the priority. The inventory owner signs off the inventory each quarter. Every change that follows goes through your change board, and the migration plan is approved by the risk committee and the board. The agent's permissions are enforced by the platform's identity and policy controls and read-only access, not by instructions in a prompt.
Supplier evidence agent
Where a person signs offThe supplier's owner reviews and sends every question, and procurement decides on contract changes. Supplier documents are treated as untrusted input, and the agent has no tools that could act on anything they say.
Every path into your estate is read-only. Collectors run inside your network with their own scoped identities and push findings out; nothing in the cloud can reach a repository, key store or device. Each finding carries a fingerprint of where it was found, so a re-scan updates the record rather than creating a duplicate.
The inventory is linked to your CMDB by service ID, so every finding has a system and an owner. Where a system has no owner in the CMDB, the finding goes to an unowned queue that the inventory owner works through, rather than disappearing.
There is no write path from the AI to anything that matters. When an owner decides a change is needed, they raise it in your ITSM tool like any other change, and it's tested and approved there. If the AI is switched off, the inventory and plan remain, and owners keep them current by hand.
Agree scope, the classification rules and the priority factors. Pick one business service to trace end to end: its code, certificates, network path, devices and suppliers. Set up read-only access with security architecture.
Gate · must be true to passRules approved, read-only identities reviewed, inventory owner named, system owners for the pilot service agreed.
Run discovery on the pilot service. Owners confirm every finding. Compare with what the team knew before and with a manual sample.
Gate · must be true to passFinding precision and coverage within agreed limits, no write access anywhere, unknowns listed with next steps, CISO sign-off.
Extend to the rest of the high-priority services, switch on event-driven updates, and start supplier questions.
Gate · must be true to passMonitoring and audit in place, owners trained, unowned queue being worked, first draft plan reviewed by the risk committee.
Cover the full estate, keep the inventory current, and track migrations against the plan towards 2031 and 2035.
Gate · must be true to passEach new area passes the same confirmation gate; the plan is approved by the board ahead of 2028.
| Activity | CISO | Inventory owner | Solutions architectI can fill this | Technical PMI can fill this | EngineersI can fill this | System owners | Procurement |
|---|---|---|---|---|---|---|---|
| Business case and scope | Accountable | Responsible | Consulted | Consulted | Informed | Consulted | Informed |
| Classification rules and priority factors | Accountable | Responsible | Consulted | Informed | Consulted | Consulted | Informed |
| Target architecture and read-only access | Consulted | Consulted | Accountable and Responsible | Consulted | Consulted | Informed | Informed |
| Build and integration | Informed | Consulted | Accountable | Responsible | Responsible | Informed | Informed |
| Confirming findings | Informed | Accountable | Informed | Consulted | Consulted | Responsible | Informed |
| Supplier questions and contract changes | Informed | Consulted | Consulted | Consulted | Informed | Consulted | Accountable and Responsible |
| Migration plan and priorities | Accountable | Responsible | Consulted | Consulted | Informed | Consulted | Consulted |
| Run and keep current | Informed | Accountable | Consulted | Consulted | Responsible | Responsible | Informed |
R ResponsibleA AccountableC ConsultedI Informed· not involved
Option A
If there's no architect on the programme, I'd own the design end to end: the read-only discovery boundary, the inventory model, the classification rules with your security team, the links to your CMDB and change process, and the gates. I'd work alongside your inventory owner and report to your programme board.
Option B
If your partner or your own team already has an architect, I'd take on the agents, the collectors and the integrations under their lead, and give them a second senior opinion on how the inventory stays current after the first push, and on how the plan holds up against your suppliers and long-lived devices.
Goes wrong
A pattern search finds 'RSA' in thousands of places, and owners are flooded with false findings.
How the design avoids it
The agent reads the context and cites evidence, precision is measured weekly, and owners confirm before anything counts.
Goes wrong
The inventory is built once as a project spreadsheet and is out of date within six months.
How the design avoids it
A living record with a named owner, events from new certificates, repositories and suppliers, and a quarterly sign-off.
Goes wrong
The agent is given rights to rotate certificates 'while it's there'.
How the design avoids it
No write tools at all. Changes go through your change board, tested like any other change.
Goes wrong
Embedded devices, plant equipment and supplier-run services are left out because they can't be scanned.
How the design avoids it
Unknowns are a tracked category with an owner, and supplier questions cover what you can't see.
Goes wrong
Priorities follow the algorithm, not the data, so long-lived secrets wait behind easy wins.
How the design avoids it
Priority factors set by people, starting with how long the data must stay confidential.
Changes already announced or under way that affect this design. More in the UK horizon scan.
If you bring in outside help for discovery, ask whether it's assured under the NCSC scheme, and make sure what it produces lands in your inventory, not a separate report.
Record algorithms precisely and keep certificate lifetimes short, so new standards mean a re-run of the rules, not a new inventory.
Have the inventory confirmed for high-priority systems and the plan in front of the board before then.
Start with what's easiest to switch on, such as hybrid key exchange where your software already supports it, while the harder changes are planned.
Ask suppliers now for dates, and stop buying products that can't be updated before then.
Good answers are specific. Vague answers to any of these are worth following up.
Whether you need someone to lead the design or to support the architect you already have, let's talk it through.