Most organisations worry about the confidentiality of their data for a few years. Healthcare providers have to think in decades. A maternity record in England is kept for 25 years, a cancer record for 30, and a diagnosis does not stop being sensitive when the retention period ends. That long shelf life is what makes post-quantum readiness in healthcare a practical concern now, not a future research topic.
NIST makes the point directly. Its final NIST IR 8547 (October 2026) explains the “harvest now, decrypt later” threat and says it underscores the need to act immediately, “especially for data with long-term sensitivity, such as government secrets or medical records.” Add connected medical devices that stay in service for years with cryptography fixed at manufacture, and healthcare has one of the longest post-quantum exposure windows of any sector.
This article sets out why, which regulatory signals point the same way, and a practical plan to get started.
Why Healthcare Has a Long Confidentiality Horizon
Retention schedules are the best available evidence of how long health data must be protected. The NHS England Records Management Code of Practice sets these minimum periods for care records:
| Record type (England) | Minimum retention |
|---|---|
| Adult health records not covered elsewhere | 8 years |
| Children’s records | Until the 25th birthday, or 26th if the patient was 17 when treatment ended |
| Obstetrics and maternity records | 25 years |
| Mental health records | 20 years, or 10 years after death |
| Cancer and oncology records | 30 years, or 8 years after death (from diagnosis) |
| GP records of deceased patients | 10 years |
In the United States the picture is fragmented. The HIPAA Security Rule requires covered entities to keep their security policies and documentation for six years (45 CFR 164.316), but the retention period for the medical record itself is largely set by state law and varies widely.
Retention is only a floor. Confidentiality often matters for the rest of a patient’s life, and genetic data is sensitive for their relatives too. UK GDPR treats data concerning health and genetic data as special category data (Article 9) and requires security appropriate to the risk, taking account of the state of the art (Article 32). If data protected by today’s public-key cryptography is captured in transit now, a future quantum computer could expose it while it is still sensitive. For background on that threat, see our article on post-quantum threats.
Where Harvest-Now-Decrypt-Later Bites in a Hospital
The exposure is concentrated wherever patient data crosses a network using classical key exchange such as RSA or elliptic-curve Diffie-Hellman:
- HL7 and FHIR interfaces between the EHR, labs, pharmacy and partner organisations
- DICOM image transfers between modalities, PACS and reporting sites
- Health information exchange and referral links to other providers
- Site-to-site and remote-access VPNs, including supplier support connections
- Replication and backup traffic to cloud or secondary data centres
- Research and genomic data transfers to academic partners
Symmetric encryption at rest, such as AES-256, is not the main concern. The priority is key establishment on links that carry long-lived records. Quantum Sentinel, a Sinevis technology partner, makes a similar case on its healthcare industry page, which maps cryptography across EHR and PACS databases, FHIR and DICOM interfaces, connected devices, enterprise PKI and research data stores, and highlights long-retention and genomic data as the highest harvest-now-decrypt-later exposure.
Connected Medical Devices: Long Lifecycles, Embedded Cryptography
Infusion pumps, imaging systems, patient monitors and implantables often stay in service for many years, with cryptographic libraries, keys and certificates built in at manufacture. Some cannot be patched without a regulatory resubmission, and some cannot be patched at all.
The US Food and Drug Administration’s guidance Cybersecurity in Medical Devices: Quality Management System Considerations and Content of Premarket Submissions, issued on 3 February 2026 to align with the new Quality Management System Regulation, addresses this directly. It recommends that manufacturers use current NIST-recommended cryptography, or equivalent protection, “expected to be considered cryptographically strong throughout the service life of the device,” and that they avoid algorithms deprecated or disallowed in standards such as NIST SP 800-131A. It also covers section 524B of the Federal Food, Drug, and Cosmetic Act for “cyber devices”, including a software bill of materials. With NIST now set to deprecate quantum-vulnerable public-key algorithms after 2030, a device designed today with RSA or ECDSA alone will struggle to meet that service-life test.
For providers, the UK NCSC’s migration timelines guidance (20 March 2025) describes the same constraints for IoT and operational technology: devices may be resource-constrained, hard to upgrade or not designed to be replaced. That makes procurement the main lever. Every new device contract is a chance to require post-quantum capability, or at least a credible upgrade path.
Regulatory Signals Pointing the Same Way
No healthcare regulation yet mandates post-quantum cryptography by name, but the direction is clear:
- HIPAA Security Rule proposal (US). The proposed rule published on 6 January 2025 would make encryption of ePHI at rest and in transit required, with limited exceptions, rather than addressable as it is today. It would also require a written technology asset inventory and network map, and it includes a request for information on quantum computing that notes the threat to asymmetric cryptography. The current regulatory agenda lists final action for July 2027, so this is a signal, not yet an obligation.
- NIST IR 8547 (US). Final since October 2026: quantum-vulnerable public-key algorithms deprecated after 2030 and disallowed after 2035, with medical records named as an example of long-term-sensitive data.
- NCSC timelines (UK). Complete discovery and an initial migration plan by 2028, highest-priority migration by 2031 and full migration by 2035.
- FDA premarket cybersecurity guidance (US). Cryptography expected to remain strong for the device’s service life.
The common thread is evidence: an accurate inventory of where cryptography is used and a defensible plan to change it. Quantum Sentinel’s compliance use case focuses on that output, an audit-ready cryptographic inventory and reporting aligned to major frameworks.
A Practical Plan for Post-Quantum Readiness in Healthcare
- Map shelf-life to systems. Use your records retention schedule as the starting point. Tag each clinical system and data flow with the longest retention period of the data it holds or carries. This turns a vague risk into a ranked list.
- Discover the cryptography. Build a cryptographic inventory across EHR, PACS, integration engines, VPNs, PKI and, where safe, connected devices. Our guide to the Cryptographic Bill of Materials explains the structure. Quantum Sentinel’s CBOM discovery exports a CycloneDX 1.7 inventory using read-only collection that does not retrieve key material, which matters in clinical environments.
- Prioritise by exposure and clinical impact. Rank findings by data shelf-life, network exposure and clinical criticality, not by algorithm alone. Start with external and partner-facing links that carry long-retention data.
- Fix procurement now. Ask device manufacturers and software suppliers for their post-quantum roadmap, the cryptography in their SBOM, and whether algorithms can be updated in the field. Make crypto-agility a contract requirement for new purchases.
- Plan around clinical lifecycles. Align migration with planned replacements and upgrade windows rather than forcing changes on live clinical systems. Quantum Sentinel’s migration planning use case attaches a priority and a named replacement algorithm to each finding, with ticket creation in Jira, ServiceNow ITSM and BMC Helix ITSM, while the plan itself stays with your team.
For the broader programme view, see post-quantum migration readiness in 2026, or take our free PQC compliance check for a quick baseline.
How Sinevis Can Help
Sinevis delivers post-quantum readiness assessments that start from your data retention obligations and clinical priorities. We work with Quantum Sentinel for automated cryptographic discovery and a continuously updated CBOM, and with Nozomi Networks to give visibility and threat detection across healthcare IoT and connected medical devices, so device risk is assessed alongside the rest of the estate. Both are among our technology partners.
To discuss a post-quantum readiness assessment for your organisation, contact the Sinevis team.
Sources
- NIST, NIST IR 8547, Transition to Post-Quantum Cryptography Standards (final), October 2026
- NHS England, Records Management Code of Practice, Appendix II: Retention schedule, care records, page last edited 20 May 2026
- US Government, 45 CFR 164.316, Policies and procedures and documentation requirements, eCFR
- US Department of Health and Human Services, HIPAA Security Rule To Strengthen the Cybersecurity of Electronic Protected Health Information (proposed rule), Federal Register, 6 January 2025
- Office of Information and Regulatory Affairs, Unified Agenda entry RIN 0945-AA22
- US Food and Drug Administration, Cybersecurity in Medical Devices: Quality Management System Considerations and Content of Premarket Submissions, 3 February 2026
- UK National Cyber Security Centre, Timelines for migration to post-quantum cryptography, 20 March 2025
- legislation.gov.uk, UK GDPR Article 9 and Article 32