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Policy Brief: Government Procurement of Quantum Services — What FedRAMP and BigBear.ai Teach Us

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2026-02-17

11 min read

How governments should procure quantum services in 2026: balance FedRAMP approval with auditability, PQC, and anti–vendor lock-in measures.

Policy Brief: Government Procurement of Quantum Services — Lessons from FedRAMP and BigBear.ai

Hook: Agencies and technology leaders face a familiar dilemma in 2026: quantum services promise capability leaps for modeling, optimization and cryptanalysis, but procurement is fraught with security, auditing and vendor-lock-in risks. With limited real-hardware access, fragmented SDKs and rising regulatory scrutiny, governments must build procurement rules that unlock quantum innovation while preserving control, auditability and transition options.

Executive summary

Recent market moves — including BigBear.ai’s late-2025 acquisition of a FedRAMP-approved AI platform and the expanding ecosystem of cloud marketplaces — show how authorization can accelerate government uptake of advanced services. But FedRAMP approval alone is not a panacea. This brief lays out precise procurement guardrails for quantum services in 2026, including security baselines, continuous auditing, vendor lock-in mitigation, contract language, and technical annexes specific to quantum-as-a-service (QaaS). The goal: enable agencies to buy quantum capabilities quickly, securely, and with clear exit and reproducibility paths.

Why this matters now (2026 context)

By 2026 the federal technology landscape has two converging dynamics relevant to quantum procurement:

FedRAMP continues to expand its influence: agencies increasingly prefer FedRAMP-authorized platforms because those platforms reduce authorization-to-operate (ATO) timelines. High-profile acquisitions (e.g., BigBear.ai’s purchase of a FedRAMP-approved AI platform in late 2025) demonstrate how market players use FedRAMP status as a de facto entry ticket into government contracts.
Post-quantum and zero-trust realities: the NIST-led post-quantum cryptography transition and federal Zero Trust mandates (2021–2025 rollouts) mean agencies must treat cryptographic resilience and identity as central procurement criteria for any cloud or hybrid quantum service.

These forces lower the barrier to vendor onboarding but raise the stakes: when a vendor with FedRAMP status is acquired or financially unstable, agencies inherit complex compliance, supply-chain and continuity risks. Procurement policy must therefore be proactive, not reactive.

Case study: BigBear.ai — rapid access vs. governance complexity

In late 2025 BigBear.ai announced elimination of debt and the acquisition of a FedRAMP-approved AI platform. That move highlights a template for agencies: acquiring platforms with FedRAMP authorization can be an efficient path to capacity. But it also illustrates three procurement lessons:

Authorization is portable, but obligations travel with the asset. The acquiring company must maintain continuous monitoring, reporting and control ownership; agencies must verify that controls continue to meet the original ATO assumptions.
Financial instability of vendors introduces supply-chain risk. An acquiring vendor with weak revenue or shifting strategy can deprioritize governmental compliance or alter pricing and SLAs.
FedRAMP status reduces friction but does not replace contract-level audit rights or exit mechanisms. Agencies still need explicit audit, data export, escrow, and transition clauses.

FedRAMP approval accelerates procurement but is necessary, not sufficient, for secure quantum service adoption.

2026 trends shaping quantum procurement

Market consolidation & M&A: more startups are being bundled by larger cloud or defense contractors — agencies will often inherit services through vendor acquisitions.
Hybrid QaaS models: federated access to hosted hardware, local emulators and hybrid simulators has become common; procurement must cover both hosted hardware access and sandboxed simulators.
Open standards pressure: OpenQASM, QIR and interoperable SDKs are maturing — agencies can demand open formats to reduce lock-in.
Data & model marketplaces: inspired by late-2025 AI data marketplace trends, procurement needs to handle datasets, model provenance and paid access to training/benchmark data for quantum ML.
Post-quantum cryptography: agencies must require PQC-ready key management and migration plans for models and datasets that may be attractive targets for retrospective decryption.

Core procurement principles for quantum services

Below are foundational policy principles agencies should incorporate into solicitations, RFPs and contract awards.

1. Require baseline authorizations and continuous evidence

Mandate FedRAMP authorization level appropriate to data sensitivity (e.g., FedRAMP Moderate for most research, FedRAMP High for classified or high-impact workloads).
Include clauses for continuous monitoring evidence, weekly or monthly control reports, and immediate notification of any authorization-affecting change (ownership, subcontracts, control failures).

2. Specify cryptographic & key-management requirements

Require support for post-quantum cryptography (PQC) or hybrid classical+PQC schemes for at-rest and in-transit protections where data sensitivity warrants.
Mandate integration with agency key management systems (cloud HSM / on-prem KMS) or customer-managed keys. No vendor-only-only KMS without explicit justification.

3. Enforce auditability and forensic-ready logging

Demand tamper-evident logging, immutable job records, job-result hashes and a chain-of-custody ledger for quantum jobs and outputs.
Require SIEM integration capability, exportable logs, and a schedule for audit-support windows (e.g., 90 days for immediate logs, archival for X years depending on policy).

4. Build explicit anti–vendor lock-in clauses

Require export of experiment packages, circuit descriptions (OpenQASM/QIR), and datasets in open, documented formats without additional fees.
Include transition and exit terms (data escrow, transfer assistance, dual-run period) that survive a change of control.

5. Require supply-chain transparency and SBOMs

Vendors must provide a Software Bill of Materials (SBOM) for both classical control software and firmware used in quantum hardware or simulators.
Flow-down requirements to subcontractors for third-party components and hosted services, and clear supply-chain transparency to detect intermediated risks.

Actionable procurement checklist (what to include in RFPs and contracts)

Use this checklist as insertable language in solicitations and contracts. Each item maps to a clause or annex.

FedRAMP & Authorization
- Vendor must hold current FedRAMP authorization at or above [insert level]. Provide authorization package and post-authorization continuous monitoring plan.
Change-of-control & acquisition notification
- Vendor must notify the agency within 7 days of any intended or completed change of ownership. The agency reserves the right to re-evaluate the ATO, SLAs and pricing and to require transition assistance.
Data portability & open formats
- All circuits, experiment metadata, results and raw data must be exportable in documented, open formats (OpenQASM, QIR, HDF5 or agreed JSON schema) without vendor-only tools.
Audit & forensics
- Provide API and human-accessible audit logs for job submission, execution times, results, and administrative actions. Retain logs for [X] years.
Transition & escrow
- Maintain an escrow of critical artifacts (source for vendor control plane, job queuing metadata, export tools) with an approved escrow agent. Define escrow release conditions (bankruptcy, change-of-control, failure to meet SLAs).
Security testing & vulnerabilities
- Allow agency or third-party pen testing on the service boundary and provide a coordinated vulnerability disclosure program with 72-hour critical response SLAs.
Pricing & termination
- Cap price increases on change of control for a fixed period (e.g., 12 months) and include termination for convenience with vendor-funded migration assistance.

Quantum-specific technical annex (must-haves)

Attach a technical annex to the contract that covers the unique properties of quantum services.

Job integrity and reproducibility

Require canonical job descriptors (OpenQASM/QIR) and a job hash recorded at submission and after completion.
Support seeded randomness and record seed values for reproducibility where applicable.

Hardware vs. simulator differentiation

Clearly label hardware backend vs. simulator runs. Billing and SLAs must differentiate queue wait times, calibration windows and noise profiles.
Provide historical calibration and noise data for any hardware used for results that will influence policy or spending decisions.

Benchmarking & performance reporting

Vendors must provide standardized benchmarks and raw metrics for device performance (T1/T2 equivalents, gate fidelities, crosstalk reports), updated at regular intervals.
Require third-party benchmark validation or allow agency-run benchmarking on delivery to confirm performance claims.

Auditing and continuous monitoring: practical expectations

Auditing quantum services requires both classical and specialized data flows. Agencies should:

Integrate vendor logs into agency SIEM and specify log formats and retention.
Require digital signatures for job submission and results where authenticity is critical.
Specify periodic compliance audits mapped against NIST SP 800-53 controls and FedRAMP control families.
Demand transparency into calibration and firmware updates affecting reproducibility.

Mitigating vendor lock-in: strategies that work

Vendor lock-in is the biggest practical barrier to confident procurement. Here are proven strategies to reduce it:

Multi-vendor procurement and federated buying

Prefer contracts that allow and budget for multiple providers. Running experiments across several vendors — classical cloud simulators and different hardware backends — both reduces reliance on any single supplier and provides cross-validation.

Open interfaces and exportability

Require APIs adhering to open standards and explicit exportability of workloads, datasets and experiment metadata. Clauses should forbid the vendor from deploying proprietary-only client tooling as the only export path.

Containerization and local emulators

Where possible, require that vendors provide containerized emulators or reference implementations that can be run on-premises for development and archival reproducibility.

Data, model & provenance escrow

Store critical datasets, models and provenance logs in escrow with conditions for release. This protects agencies if a vendor ceases operations or changes direction post-acquisition.

Governance: who must be involved

Quantum procurement demands cross-functional governance:

Chief Information Security Officer (CISO) — approves security baselines and continuous monitoring requirements.
Acquisition & contracting officers — embed specialized clauses and manage change-of-control risks.
Technical review board — ensures standards for reproducibility, open formats and benchmarking.
Legal & policy — ensures data sovereignty, licensing and export controls compliance.
Program managers — drive multi-vendor strategies and transition planning.

Sample RFP snippets (copy-paste friendly)

Use these short clauses directly in solicitations.

FedRAMP & continuous monitoring

"Vendor must maintain an active FedRAMP authorization at the [insert level] and submit monthly continuous monitoring reports, including control status, major incidents, and change logs. Any change of control must be reported within seven (7) calendar days and triggers an agency re-evaluation of the ATO and contract terms."

Data export & transition assistance

"Upon contract termination or agency request, vendor must provide all customer data, job descriptors, experiment metadata, and result files in open formats (OpenQASM/QIR or vendor-neutral JSON) and provide 90 calendar days of transition assistance. Critical artifacts will be placed in escrow per the attached escrow schedule."

Audit & penetration testing

"Agency retains the right to perform or contract third-party penetration tests once per annum. Vendor must remediate critical findings within 14 days and provide result confirmation to the agency."

Implementation roadmap for agencies (90/180/365 days)

0–90 days: Update RFP templates to include FedRAMP-authorization requirements, basic anti–lock-in clauses, and escrow language. Start vendor inventory and identify existing FedRAMP-accredited platforms in use.
90–180 days: Run a multi-vendor pilot for at least two representative workloads (one research/experiment, one production/analysis) with two QaaS providers. Verify exportability and logging integration.
180–365 days: Formalize continuous monitoring dashboards, integrate vendor logs into SIEM, and establish recurring third-party benchmarking and audit cadences. Negotiate transition guarantees into long-term contracts.

Top 10 policy recommendations

Always require FedRAMP authorization at an appropriate level and verify continuity after any M&A event.
Mandate post-quantum-ready key management and customer-managed keys where data sensitivity demands.
Include explicit change-of-control clauses and price stability provisions for at least 12 months post-acquisition.
Enforce open formats (OpenQASM/QIR) and exportability for experiment portability.
Use escrow for critical artifacts (source code, export tools, datasets).
Require SBOMs and subcontractor flow-down for hardware/firmware and control software.
Integrate vendor logs into agency SIEM and require tamper-evident logging for jobs/results.
Fund multi-vendor pilots to reduce reliance on any single provider.
Require vendor cooperation for audits and quarterly benchmarking.
Build a cross-functional governance body (security, contracting, technical, legal) to evaluate quantum procurements.

Conclusion: make FedRAMP a starting line, not the finish

FedRAMP authorization and the strategic acquisition of FedRAMP-approved platforms (as seen in the BigBear.ai example) accelerate access to quantum-adjacent services for government use. But the 2026 procurement environment demands more: explicit clauses for continuous monitoring, PQC readiness, auditability, reproducibility and transition must be embedded in every contract. Agencies that treat FedRAMP as the beginning of governance — and that demand open standards, multi-vendor strategies, and escrowed artifacts — will enjoy rapid access to quantum capabilities without sacrificing security, auditability or control.

Actionable takeaway: Update RFP templates this quarter to include FedRAMP level requirements, exportability in OpenQASM/QIR, escrow terms and change-of-control notifications. Launch a two-vendor pilot and require vendor-provided SBOMs before contract award.

Call to action

Need a deployment-ready RFP template, contract annexes or a 90-day pilot plan tailored to your agency? Contact our team at QBitShared Consulting for a policy-ready package that maps FedRAMP controls to quantum-specific procurement clauses and provides sample legal language, technical annexes, and audit playbooks.

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