FS-ISAC Issues New Guidance to Help the Payment Card Industry Mitigate Risks of Quantum Computing

Feb. 20, 2025

Payments Industry Also Grapples with Fast-Approaching PCI-DSS 4.0 March 2025 Deadline 

In an era where technological advancements are rapidly transforming industries, the advent of quantum computing stands out as a double-edged sword for the payment card industry (PCI). While it promises to revolutionize complex computations, it also poses significant threats to current cryptographic methods that secure payment transactions. 

Quantum computers, with their unparalleled processing power, have the potential to break many of the encryption algorithms that currently protect sensitive payment data. This vulnerability could expose cardholder information to malicious actors, undermining the trust and security that underpin the global payment system. 

Back in June 2023, Hudson Institute’s Quantum Alliance Initiative calculated the damages of a quantum-enabled attack on U.S. financial institutions, estimating a direct loss of 10-17% GDP and between and $3.3 trillion in indirect losses, potentially propelling the country into a catastrophic economic event much like the Great Depression.

Recognizing this imminent challenge, on Feb. 13, 2025, the Financial Services Information Sharing and Analysis Center (FS-ISAC) proactively released comprehensive guidance to help the PCI navigate and mitigate the risks associated with quantum computing, emphasizing that transitioning to quantum-resilient cryptography is not just a technical necessity but a strategic imperative for the industry.

FS-ISAC’s Proactive Measures
To address these challenges, FS-ISAC’s Post Quantum Cryptography Working Group has developed a series of insightful papers tailored for both business leaders and technical practitioners within the PCI. These documents provide a roadmap for understanding and implementing quantum-resistant cryptographic solutions.

Quantum Xchange has also written extensively on how the payments industry can better manage cryptographic risk, especially with the PCI DSS 4.0 (Payment Card Industry Data Security Standard) compliance deadline for full implementation being March 2025. See our blog post, Going Beyond PCI-DSS 4.0 to Redefine Cryptographic Compliance in Finance.

Key Recommendations for Business Leaders
FS-ISAC’s flagship paper, “The Impact of Quantum Computing on the Payment Card Industry,” offers strategic insights for executives and decision-makers. It underscores the urgency of adopting quantum-resilient cryptography and outlines critical steps, including:

  • Implementing Robust Access Controls: Ensuring that only authorized personnel have access to sensitive cardholder data.
  • Encrypting Data in Transit and at Rest: Protecting data throughout its lifecycle to prevent unauthorized access.
  • Regular System Updates and Patches: Maintaining up-to-date systems to defend against emerging threats.
  • Adopting Secure Coding Practices: Developing software with security as a foundational principle.
  • Conducting Comprehensive Risk Assessments: Identifying and addressing vulnerabilities proactively.

Technical Guidance for Practitioners
For those on the front lines of implementation, FS-ISAC has developed three detailed use case papers that delve into the technical nuances of migrating to quantum-resilient cryptography, offering insights into current industry standards, potential vulnerabilities, and actionable steps to achieve quantum resilience. These documents cover:

  • Card Provisioning Setup and Cardholder Data Provisioning: Exploring the cryptographic assumptions and necessary transitions in the initial stages of card issuance and data management.
  • Transaction Routing and Authorization: Analyzing the impact of quantum computing on both card-present and card-not-present transactions, offering mitigation techniques to ensure secure processing.
  • ATM and POS Systems: Addressing the vulnerabilities in Automated Teller Machines and Point of Sale systems and providing strategies for secure setup and backend integration.

The Imperative of Early Adoption
Transitioning to quantum-resistant cryptographic standards is a complex and resource-intensive endeavor. However, the cost of inaction could be far greater, potentially leading to widespread security breaches and loss of consumer trust. 

As Oscar Covers, Policy Advisor Cyber Security of the Dutch Banking Association, aptly notes, “By developing a quantum migration strategy early, firms can save a lot of money and create a safety net that minimizes the risk of disruptions.” 

Quantum Xchange applauds FS-ISAC in its efforts to educate the industry by offering comprehensive guidance to navigate this complex landscape. Using a risk assessment tool like CipherInsights from Quantum Xchange, organizations can meet the cryptographic requirements in PCI-DSS 4.0, and those outlined by FS-ISAC, that enforce the need for strong cryptography, annual inventory, and security protocols (see solution brief). Then use Phio TX to deploy and manage NIST-standard Post-Quantum Cryptography (PQC) algorithms within their existing infrastructure for immediate quantum safety. 

By integrating the practices shared by FS-ISAC and technologies from Quantum Xchange, PCI organizations can begin to fortify their defenses against the potential disruptions posed by quantum computing, ensuring the trust and safety of every transaction today and in the quantum future. 

Subscribe to the Quantum Xchange Monthly Newsletter

Quantum Xchange does not share or rent your information to any third parties.