"Future versions" of Android turn out to be 6.0 and onward. While this requirement is stated as SHOULD for this version of the Android platform, it is very strongly RECOMMENDED as we expect this to change to MUST in the future versions of Android.
But they did make it clear that the change was almost definitely coming, just not yet, saying at the time: Two months later, Google revised the CDD and decided it would no longer mandate encryption, merely "strongly recommend" it. Since the announcement of encryption being enabled by default of the Nexus 6 and Nexus 9, Google has been on the encryption warpath (rightfully so!), and did in fact attempt to make this change in the initial Lollipop CDD back in January.
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