M13 / Migration program

Supply chain and governance: vendor lock-in, RACI, KPIs

Advisor

After this lesson you can

  • List the areas a vendor questionnaire must cover (PQC roadmap, certification status, crypto-agility support) and explain that a supplier can be the slowest link
  • Place vendor lock-in risk (including the possibility that a vendor profits from delaying its PQC timeline), RACI, KPIs and board/regulator reporting into a migration program's governance structure

Before thisThe cost model: methodology and the corpus's own provenance lesson

Mental model

In the previous two lessons you built a roadmap (three horizons) and a cost methodology. This last M13 lesson focuses on governance: who is responsible for the program and how dependent it is on suppliers.

The vendor questionnaire: four areas

A migration program almost always depends on third-party suppliers (HSM vendors, CAs, TLS and crypto library providers, payment processors); so a vendor questionnaire should be an early step in the program. Four areas should be covered: (1) roadmap and dates, a concrete version number and date commitment (as you saw in M5, not “soon” but something like “in version X.Y, in quarter Q”); (2) which algorithms are supported at which status, applying M5’s status discipline (FINAL/DRAFT/SELECTED and so on) directly to the vendor; (3) crypto-agility architecture, whether there is an abstraction like the provider model you saw in M12, or whether an algorithm change depends on the vendor’s own product update; (4) certification status, at which stage a certification such as FIPS 140-3 or Common Criteria is (like M5’s CAVP/CMVP distinction).

Vendor lock-in: who benefits from delay

A risk specific to PQC migration: a vendor can profit by delaying its own transition, because the longer the customer stays dependent on the vendor’s existing, proprietary integration, the higher the cost of switching vendors. This is not an accusatory assumption (most vendors do not delay deliberately; there are real engineering difficulties), but trusting a vendor’s own roadmap statement without questioning whether this motivation might exist is a weak governance position. The practical response: tie concrete commitments to the contract (an SLA, service level agreement), ask for independent verification (third-party certification, a public roadmap page, not just the sales representative’s word), and keep a fallback or exit plan (an assessment of alternative vendors) for critical suppliers.

RACI: making supplier dependency visible

In a RACI matrix (Responsible, Accountable, Consulted, Informed), supplier-dependent work items must be marked explicitly: for example, an HSM firmware update is controlled not by a team inside the institution but by the vendor’s own delivery schedule. Planning this item on the same RACI line, with the same confidence, as an internal task leads to an assumption of control that does not really exist (the same logic as the dependency graph principle in M13’s first lesson, this time applied to supplier dependency).

KPIs and reporting

To track a migration program’s progress, at least these KPIs (key performance indicators) are meaningful: percentage of systems completed (in each of H1/H2/H3, the number of systems migrated over the total), supplier commitment fulfilment rate (how many of the dates vendors gave were really kept, a confidence score based on past performance), and number of high-risk systems remaining (how many critical systems, such as the 4 payment surfaces that really need PQC from M10, are still waiting for migration). Board reporting should present these KPIs tied to the three-horizon structure from M13’s first lesson: concrete, traceable language such as “80% of H1 is complete, the start of H2 was delayed by 2 months because of a supplier delay” is more trustworthy than vague language such as “overall we are doing well”. The same discipline applies to regulator communication: the progress presented to the regulator must rest on the same numbers as the internal KPIs, with no separate “external face” narrative.

Numbers to know

  • The four main areas of a vendor questionnaire: (1) the PQC roadmap and dates (is there a concrete version/date commitment, or a vague 'soon'), (2) which algorithms are supported at which status (apply M5's status discipline to the vendor), (3) crypto-agility architecture (is there an abstraction like the provider model in M12), (4) certification status and timeline, such as FIPS/CC
  • The PQC-specific risk of vendor lock-in: a vendor can profit from delaying its own PQC transition by keeping the customer dependent longer on its old, proprietary integration; questioning that motivation means asking for independent evidence (third-party certification, a public roadmap commitment) instead of trusting the vendor's own statement

Lab: Assess your own vendor list with the four-part frame

[not run] This is a governance and vendor assessment exercise, not a runnable command

Requires: . Check your setup

shell
# List your bank's critical crypto vendors (HSM vendor, CA, TLS library provider), fill in the four areas (roadmap, status, agility, certification) for each, and mark which is the 'slowest link'
Recorded output
A table: vendor, scores on the four areas, a slowest-link marker, and which H1/H2/H3 tasks depending on this vendor are at risk

At the table

How to say this in a bank meeting.

To an executive
Our migration program's speed is limited by the speed of our slowest supplier; so vendor management is as critical a governance piece as the technical part of the migration program, not just a procurement detail.
To an architect
For certain work items the RACI matrix may need to put the supplier not as 'Informed' but as an 'Accountable' party: for example, an HSM firmware update is not under the institution's own control but depends on the vendor's delivery schedule. Making this dependency visible in the RACI lets you see the delay risk early.
Objection
“"Our vendor tells us PQC support is 'coming soon'. Isn't that enough?"”
Answer
No: 'soon' is the exact opposite of the status discipline you saw in M5, a statement with no concrete version number or date commitment. Also, trusting this statement without questioning whether the vendor profits from delaying its own transition (how proprietary or locked-in your current integration is) is risky; you should ask for a concrete commitment, independent verification (like M5's CAVP/CMVP distinction), and a fallback plan (an alternative vendor).

Sources

  • NIST (NCCoE Migration to Post-Quantum Cryptography project), 2026. Section 5.3 'Technology Supply Chains' directly addresses bringing technology providers in the supply chain into the governance function, prioritized by criticality; NIST-sourced evidence that migration is a supply-chain-wide governance problem, not an internal one. Note: NIST's own term is 'supplier dependency / supply chain governance', not 'vendor lock-in'; this lesson's lock-in analysis and RACI/KPI frame go beyond this source and are this course's own synthesis

    Section 5 (Crypto Agility Strategic Plan, governance function); Section 5.3 (Technology Supply Chains) / 15 min

Checkpoint

Answer first, then compare with the model answer and score yourself against the rubric. Saved in this browser only.

  1. 01Recall

    What are the four main areas of a vendor questionnaire?

  2. 02Recall

    What is the PQC-specific risk of vendor lock-in, and why might a vendor want to delay its transition deliberately?

  3. 03Scenario

    An HSM vendor gives no concrete date for a PQC firmware update, only saying 'it's on our roadmap'. How do you show this dependency in the RACI, and which KPI do you track it with?

  4. 04Hostile

    A regulator asks 'What is the governance structure of your migration program? Who is responsible for what?' Explain RACI, KPIs and supplier dependency management together.

Project linkContributes the vendor questionnaire template, the RACI skeleton and the KPI set directly to the governance section of Project 4's (capstone) migration roadmap.