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A04:2025 - Cryptographic Failures - Reconsider Placement - Should be higher considering known PQC & Cryptographic Agility Gaps #849

@TimDWilliams-ProteQC-CTO

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TLDR;
This Issue argues, based on cited evidence, that it would be wrong for OWASP to reduce the priority of Cryptographic Failures by 2 places between the OWASP Top 10:2021 and the OWASP Top 10:2025 and that Cryptographic Failures need, for the reasons provided, to be ranked 1 in the OWASP Top 10:2025.

Per the release candidate text for A04:2025 (https://owasp.org/Top10/2025/0x00_2025-Introduction/) "The contributed data indicates that, on average, 3.80% of applications have one or more of the 32 CWEs in this category" while the release candidate text for A01:2025 states "the contributed data indicates that on average, 3.73% of applications tested had one or more of the 40 Common Weakness Enumerations (CWEs) in this category".

Clearly prevalence in historic data is only one of many factors which must be considered in determining the OWASP Top 10 descending priority order.

However, the proposed "demotion" of cryptographic failures from "A02:2021" to "A04:2025" signals the very opposite of the upwards global trend in the significance of cryptographic vulnerabilities at the time of publication of this current release of the OWASP Top 10 which can only be expected to rise over the coming three to four years until the next OWASP Top 10 is published.

Not only did NIST publish the first 3 approved royalty-free Post Quantum Cryptography (PQC) algorithms (https://en.wikipedia.org/wiki/Post-quantum_cryptography) in August 2024 (https://www.nist.gov/news-events/news/2024/08/nist-releases-first-3-finalized-post-quantum-encryption-standards) which now need to be rolled-out globally and not only did OpenSSL release v3.5 with PQC support in April 2025 (https://openssl-foundation.org/post/2025-04-22-pqc/), but multiple governments and security agencies have issued advisories alerting stakeholders of the importance of starting comprehensive cryptographic discovery and inventory work without delay and migrating significant systems to PQC algorithms by 2030 (https://digital-strategy.ec.europa.eu/en/library/coordinated-implementation-roadmap-transition-post-quantum-cryptography, https://www.ncsc.gov.uk/guidance/pqc-migration-timelines, https://www.cyber.gov.au/sites/default/files/2025-09/Planning%20for%20post-quantum%20cryptography%20%28September%202025%29.pdf, https://www.fsisac.com/hubfs/Knowledge/PQC/PQC%20Timelines.pdf?hsLang=en).

The Global Risk Institute has been publishing Quantum Threat Timeline reports annually since 2019 (most recently in 2024 https://globalriskinstitute.org/publication/2024-quantum-threat-timeline-report/) warning of the need to update cryptographic algorithms.

The EU Digital Operational Resilience Act (DORA) which came into force on 12th January 2025 requires 22,000 regulated financial entities to manage cryptographic risks including "threats from quantum advancements" (Ref: Regulatory Technical Standard for ICT Risk Management Recital 9 (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401774#rct_9) and needing to be able to "change or replace cryptographic mechanisms in response to developments in cryptographic analysis (Ref: Regulatory Technical Standard for ICT Risk Management Article 6.4 (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401774#art_6).

Moreover the United Nations declared Quantum 2025 (https://quantum2025.org) and this year multiple vendors have announced breakthroughs in Quantum Computing QuBit capacity signalling that the famous 1994 factorisation algorithm of Peter Shor (https://en.wikipedia.org/wiki/Shor%27s_algorithm) and the famous 1996 search algorithm of Lov Grover (https://en.wikipedia.org/wiki/Grover%27s_algorithm) are likely to become practical possibilities sooner than expected.

Furthermore there are also very significant extended supply chain issues associated with PQC migrations (https://www.etsi.org/deliver/etsi_tr/103600_103699/103619/01.01.01_60/tr_103619v010101p.pdf, https://media.defense.gov/2023/Aug/21/2003284212/-1/-1/0/CSI-QUANTUM-READINESS.PDF) meaning in the context of the OWASP Taxonomy (which of course cannot avoid overlaps) there is a tension between raising the rank order of supply chain vulnerabilities and reducing the rank order of cryptographic vulnerabilities. Arguably the best way to resolve this would be by a strong 1, 2 ordering of Cryptographic Vulnerabilities (with forward signposting of supply chain aspects) followed by Supply Chain vulnerabilities (with backward signposting of Cryptographic aspects) resulting in a very clear and coherent opening to the OWASP Top 10 narrative flow.

For OWASP to signal in the final 2025 version of OWASP Top 10 that cryptographic vulnerabilities are decreasing in importance just as the most significant challenges in deploying new cryptographic algorithms to have been necessary over the last 25 years since the TLS 1.0 spec was approved in 1999 and the RSA algorithm went out of patent in 2000 would send misleading messages to OWASPs global reliance community and likely be harmful to OWASP's long term reputation and influence because it would become increasingly obvious over the period of this release that the demotion of cryptographic weaknesses was not justified.

I would therefore advocate strongly for Cryptographic failures not to be demoted from priority rank order 2 and to be increased to priority rank order 1. At the very least Cryptographic failures should not be ranked lower by OWASP in 2025 than they were in 2021.

Now I need at this point to declare a potential conflict of interest, so that this argument can be considered on its merits and the preponderance of evidence not because of who wrote this issue or why I, my colleagues and other vendors working in the competitive global PQC supply chain might benefit from OWASP ranking Cryptographic Failures higher rather than lower. For full transparency I am the CTO of a recently-formed UK start-up called ProteQC.com (currently not yet fully launched) which is seeking to provide expert, vendor-neutral consultancy mainly in the financial services sector to organisations that need assistance with migrating to PQC algorithms and implementing cryptographic agility quickly, efficiently, accurately and at reasonable cost.

Finally I need to clarify that this issue is submitted with the greatest respect to all of the expert contributors who have completed all the great and necessary detailed data analysis and CWE mapping work to make this release of the OWASP Top 10 possible. These arguments are only about the high level presentation and sequencing, not about the underlying extremely rigorous and data-driven analysis.

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