HKMA · Quantum Preparedness

The HKMA wrote the playbook. ACD runs it.

In July 2026 the HKMA scored Hong Kong banking 2.3 / 10 on post-quantum readiness and published PACT — a complete framework for the transition to post-quantum cryptography. ACD is the discovery layer that makes PACT's hardest step executable.

The benchmark

2.3 out of 10, with a 2030 clock.

The Quantum Preparedness Index (QPI) scores the sector across four dimensions — Awareness, Planning, Pilots and Practical Preparedness. The gap between awareness and preparedness is the whole problem.

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sector QPI score — the baseline ACD moves you off

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of banks aware, planning or piloting — but not yet prepared

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the HKMA’s full-readiness target

The whitepaper's own "four immediate steps" start with governance and end with vendors — but the middle step, commissioning a cryptographic inventory, is the one it calls the longest lead-time item. That's the step ACD collapses from months to days.

The framework

PACT — a framework for the whole journey.

PQC Accountability and Controlled Transition (a joint HKMA + HKUST framework, November 2026) organises a bank's PQC transition into four mutually supporting pillars.

Govern the transition

Institutional direction, accountable ownership and decision authority — with common requirements and demonstrated capability.

Assess and plan\u2190 ACD's pillar

Establish the current cryptographic position, assess exposure and timing, and bring plans into an integrated roadmap.

Implement and retire

Deliver authorised changes under controlled conditions and verify the approved target is achieved.

Maintain and adapt

Keep knowledge and controls current, and demonstrate the continuing ability to make further cryptographic change.

PACT groups related cryptographic uses into cryptographic estates with accountable owners, and runs on two information rails — direction and decisions down, evidence and feedback up. That evidence rail is where most tools fail.

The fit

ACD is the 'Assess and plan' pillar, automated.

PACT's second pillar begins at workstream 4.1 — establish the current cryptographic position. Every workstream in that pillar is a deterministic ACD output.

PACT workstream
What ACD ships
4.1 · Establish the current cryptographic position
Eleven-surface automated discovery → CycloneDX CBOM
4.2 · Dependency requirements and readiness
Dependency and vendor scan — who supplies your crypto, and are they ready
4.3 · Assess exposure, migration constraints and timing
Quantum verdict + Mosca risk per asset → P0–P3 priority bands
4.4 · Select the migration approach and target state
Purpose-aware mapping — RSA-sign → ML-DSA, RSA-encrypt → ML-KEM
4.7 · Agree the integrated transition roadmap
Readiness score + migration roadmap your board and auditor can act on

PACT runs on evidence. ACD produces it.

The framework's evidence-and-feedback rail can't be satisfied by a spreadsheet someone edits by hand, or a model that "probably" flags a finding. It needs deterministic, signed, re-runnable evidence — exactly what ACD emits.

Deterministic

Registry lookup, zero false positives.

Signed & reproducible

An auditor can re-run and confirm.

Continuous

Drift detection feeds the "maintain and adapt" pillar.