Most CBOM tools today scan servers, containers, source code. Enterprise IT. But the hardest cryptography to inventory lives in firmware, SaaS dependencies, OT systems with 15-year refresh cycles, and protocol defaults nobody documented. The invisible crypto is where the real migration risk lives and in custody specifically, the problem is structurally different. No central admin, distributed key material, validators running whatever they want. The enterprise CBOM playbook doesn't translate.
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The EO split — key establishment by 2030, signatures by 2031 — reflects a real engineering constraint. Key exchange is session-level: negotiate, use, discard. If ML-KEM breaks, you renegotiate. Signatures are permanent: a cert signed today is trusted for years, code signed today runs in production indefinitely. You can't un-sign. In crypto custody this is especially sharp — on-chain signatures are immutable by design. A validator signing with ML-DSA can't roll back if something goes wrong. The sequencing question in custody isn't just "when" — it's "what happens to everything you've already signed."
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Organizations don't know where their cryptography lives. It's buried in TLS configs, third-party libraries, firmware, protocol defaults nobody revisited. CBOM is supposed to fix this — but discovery alone isn't enough. Without mapping inventory to data sensitivity and regulatory exposure, you're triaging blind. Especially in crypto custody, where key material isn't behind a corporate firewall — it's on-chain, distributed, and has no central admin to push a migration. The inventory problem there is structurally different.
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