[Servercert-wg] Voting Begins: Ballot SC17 version 7: Alternative registration numbers for EV certificates
Curt Spann
cspann at apple.com
Fri May 17 12:08:26 MST 2019
Apple votes YES on SC 17.
Curt
> On May 13, 2019, at 1:16 PM, Tim Hollebeek via Servercert-wg <servercert-wg at cabforum.org> wrote:
>
> Ballot SC17: Alternative registration numbers for EU certificates
> Purpose of Ballot: Allow for the inclusion of additional information in
> certificates in order to comply with relevant EU regulations.
>
> The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
> by Dimitris Zacharopoulos of Harica and Enrico Entshew of D-Trust.
>
> Motivation:
>
> Update to CAB Forum EV Guidelines to cater for alternative registration numbers
> caused by EU Legal Requirements:
>
> i. The EU Regulation No 910/2014 (eIDAS [https://eur-lex.europa.eu/eli/reg/2014/910/oj])
> defines regulatory requirements for certificates with an agreed quality level
> called Qualified. This regulation specifies in Annex IV specific requirements
> for “Qualified certificates for website authentication” including the
> statement that the certificate shall contain: “for a legal person: the name
> and, where applicable, registration number as stated in the official records,”
>
> ii. It is understood that this requirement relates to validated attributes for
> the identification of the certificate subject and hence is best fitted in the
> subject’s distinguished name.
>
> iii. In line with the regulatory framework ETSI has defined a general structure
> for carrying “registration numbers” in TS 119 412-1
> [https://www.etsi.org/standards-search#page=1&search=TS119412-1] clause 5.1.4.
> This uses the X.520 [https://www.itu.int/rec/dologin_pub.asp?lang=e&id=T-REC-X.520-201210-S!!PDF-E&type=items]
> organizationIdentifier within the subject’s distinguished name in line with its
> stated purpose being “holds an identification of an organization different
> from the organization name”. This is used for ETSI requirements to carry
> registration numbers for certificates, Qualified or otherwise.
>
> iv. It is considered that this use of organizationIdentifier supports the primary
> purpose of EV certificates as stated in section 2.1.1 of the EV Guidelines as
> “other disambiguating information”.
>
> v. A recent EU delegated Regulation 2018/389 on secure communications for payment
> services (RTS [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R0389])
> states in Article 34.2 that for Qualified Website certificates (QWACs) the
> registration number required in eIDAS “shall be the authorisation number of the
> payment service provider … or equivalent [reference made to earlier regulations
> relating to banks]”.
>
> vi. ETSI has specified TS 119 495
> [https://www.etsi.org/standards-search#page=1&search=TS119495] requirements for
> carrying PSD2 related registration numbers in the general structure for
> registration numbers defined in TS 119 412-1 clause 5.1.4 as mentioned in
> iii. above.
>
> vii. ETSI has endeavoured to ensure and always intended that requirements relating
> to web site certificates at the Qualified level are in line with the CA/B Forum
> EV Guidelines.
>
> viii. This proposal only includes some of the Registration Schemes as used in
> ETSI TS 119 412-1, which have clear validation rules (NTR, VAT, PSD) that provide
> reasonable assurance in line with the EV Guidelines. The IPR for the semantics
> of this scheme is proposed to be released to the CA/B Forum allowing it to
> further extend the use of organizationIdentifier to include other Registration
> Schemes (e.g. LEI) and corresponding validation rules, at the CA/B Forum’s
> discretion. Also, any further changes by ETSI to ETSI TS 119 412-1 will not
> impact the CA/B Forum.
>
> ix. Having found out that CA/B Forum’s interpretation of EV Requirements in section
> 9.2.8 “Other Attributes” was not in line with those understood by ETSI experts,
> ETSI would like to harmonise with CA/B Forum approach to carrying alternative
> forms of registration number for PSD2 and other registration schemes.
>
> b) CA/B Forum specific concerns are:
>
> i. Requirements regarding Attributes to be included in the Subject DN need to be
> explicitly covered in 9.2.
>
> ii. Organisations may wish to identify OrganisationalUnits within their organisation.
> It is unclear if this is currently allowed in the EV Guidelines (similar
> ambiguity in section 9.2.8).
>
> iii. There are objections to ETSI specific usage of the orgID field (no squatting).
>
> iv. The procedures for validation of the attribute need to be clearly stated.
>
> v. There may be other uses of the organizationIdentifier field in various PKIs,
> however it is not considered to be a problem. Because of the unique semantics we
> are specifying for each identifier, applications should be able to understand
> different uses of the OrgID field by different issuers and users. There are many
> different "PKIs" out there that can use all X.500 attributes differently and with
> different validation or no validation at all. To the best of our knowledge, the
> WebPKI has never used this subjectDN attribute before for Publicly-Trusted
> Certificates. Thus there is no "conflict" by using this attribute in the EV
> Guidelines for SSL/TLS Certificates, and perhaps later for EV Code Signing
> Certificates.
>
> vi. This use of organisationIdentifier must be extendable to allow for use by other
> registration numbers allocated by different registration schemes. Some CAB Forum
> members have indicated interest in carrying registration numbers other than for
> Incorporation within EV Certificates. This is catered for in the current proposal.
>
> vii. There is interest by some CA/B Forum members in carrying LEIs within CA/B Forum
> certificates but as yet the LEI registration scheme is not currently considered
> sufficiently robust to be recognised as an registration numbering scheme to be
> accepted by CA/B Forum. Therefore this proposal only introduces a limited set of
> Registration Schemes (namely NTR, VAT, PSD) which have reasonably robust
> validation rules.
>
> viii. Some CA/B Forum members have indicated the possible need for multiple
> identifiers in the subject name. This, however, cannot be achieved using X.520
> organizationIdentifier which defined this attribute as being “SINGLE VALUE”. The
> use of a single value has the advantage is it is clear what is the registration,
> in addition to the company registration, which identifies the subject.
>
> ---MOTION BEGINS---
>
> Purpose of Ballot: Update to CAB Forum EV Guidelines to allow alternative
> registration numbers
>
> Proposed Ballot for Changes to EVG 1.6.9
>
> Add to section 4 definitions:
>
> "Legal Entity: A Private Organization, Government Entity, Business Entity, or
> Non-Commercial Entity.
>
> Registration Reference: A unique identifier assigned to a Legal Entity.
>
> Registration Scheme: A scheme for assigning a Registration Reference meeting the
> requirements identified in Appendix H."
>
> Retitle Section 9.2 as "Subject Distinguished Name Fields".
>
> Remove Section 9.2.2 and renumber sections 9.2.3 through 9.2.8 to 9.2.2 through 9.2.7.
>
> Insert new section 9.2.8:
>
> "9.2.8. Subject Organization Identifier Field
>
> **Certificate field**: organizationIdentifier (OID: 2.5.4.97)
>
> **Required/Optional**: Optional
>
> **Contents**: If present, this field MUST contain a Registration Reference for a
> Legal Entity assigned in accordance to the identified Registration Scheme.
>
> The organizationIdentifier MUST be encoded as a PrintableString or UTF8String
> (see RFC 5280).
>
> The Registration Scheme MUST be identified using the following structure
> in the presented order:
>
> * 3 character Registration Scheme identifier;
> * 2 character ISO 3166 country code for the nation in which the Registration Scheme
> is operated, or if the scheme is operated globally ISO 3166 code "XG" shall be used;
> * For the NTR Registration Scheme identifier, if required under Section 9.2.4, a two
> character ISO 3166-2 identifier for the subdivision (state or province) of the nation
> in which the Registration Scheme is operated, preceded by plus "+" (0x2B (ASCII), U+002B (UTF-8));
> * a hyphen-minus "-" (0x2D (ASCII), U+002D (UTF-8));
> * Registration Reference allocated in accordance with the identified Registration Scheme
>
> Note: Registration References MAY contain hyphens, but Registration Schemes, ISO 3166
> country codes, and ISO 3166-2 identifiers do not. Therefore if more than one hyphen
> appears in the structure, the leftmost hyphen is a separator, and the remaining hyphens
> are part of the Registration Reference.
>
> As in section 9.2.4, the specified location information MUST match the scope of the
> registration being referenced.
>
> Examples:
>
> * NTRGB-12345678 (NTR scheme, Great Britain, Unique Identifier at Country level is 12345678)
> * NTRUS+CA-12345678 (NTR Scheme, United States - California, Unique identifier at State level is 12345678)
> * VATDE-123456789 (VAT Scheme, Germany, Unique Identifier at Country Level is 12345678)
> * PSDBE-NBB-1234.567.890 (PSD Scheme, Belgium, NCA's identifier is NBB, Subject Unique Identifier assigned by the NCA is 1234.567.890)
>
> Registration Schemes listed in Appendix H are currently recognized as valid under
> these guidelines.
>
> The CA SHALL:
>
> 1. confirm that the organization represented by the Registration Reference is the
> same as the organization named in the organizationName field as specified in
> Section 9.2.1 within the context of the subject’s jurisdiction as specified in
> Section 9.2.4;
> 2. further verify the Registration Reference matches other information verified
> in accordance with section 11;
> 3. take appropriate measures to disambiguate between different organizations as
> described in Appendix H for each Registration Scheme;
> 4. Apply the validation rules relevant to the Registration Scheme as specified
> in Appendix H."
>
> Insert new section 9.8 (renumbering following sections as necessary):
>
> "9.8. Certificate Extensions
>
>
>
> The extensions listed in the Section 9.8 are recommended for maximum interoperability
> between certificates and browsers / applications, but are not mandatory on the CAs
> except where indicated as “Required”. CAs may use other extensions that are not
> listed in this Section 9.8, but are encouraged to add them to this section by ballot
> from time to time to help increase extension standardization across the industry.
>
>
>
> If a CA includes an extension in a certificate that has a Certificate field which is
> named in this Section 9.8, the CA must follow the format specified in that subjection.
> However, no extension or extension format shall be mandatory on a CA unless
> specifically stated as “Required” in the subsection that describes the extension.
>
> 9.8.1. Subject Alternative Name Extension
>
> **Certificate field:** _subjectAltName:dNSName_
>
> **Required/Optional:** Required
>
> **Contents:** This extension MUST contain one or more host Domain Name(s) owned or controlled
> by the Subject and to be associated with the Subject's server. Such server MAY be owned and
> operated by the Subject or another entity (e.g., a hosting service). Wildcard certificates
> are not allowed for EV Certificates.
>
> 9.8.2. CA/Browser Forum Organization Identifier Field
>
> **Extension Name**: _cabfOrganizationIdentifier_ (OID: 2.23.140.3.1)
>
> **Verbose OID**: {joint-iso-itu-t(2) international-organizations(23) ca-browser-forum(140)
> certificate-extensions(3) cabf-organization-identifier(1) }
>
> **Required/Optional**: Optional (but see below)
>
> **Contents**: If the subject:organizationIdentifier is present, this field SHOULD be present.
> Effective January 31, 2020, if the subject:organizationIdentifier field is present,
> this field MUST be present.
>
> If present, this field MUST contain a Registration Reference for a
> Legal Entity assigned in accordance to the identified Registration Scheme.
>
> The Registration Scheme MUST be encoded as described by the following ASN.1 grammar:
>
> id-CABFOrganizationIdentifier OBJECT IDENTIFIER ::= { joint-iso-itu-t(2) international-organizations(23) ca-browser-forum(140) certificate-extensions(3) cabf-organization-identifier(1) }
>
> ext-CABFOrganizationIdentifier EXTENSION ::= { SYNTAX CABFOrganizationIdentifier IDENTIFIED BY id-CABFOrganizationIdentifier }
>
> CABFOrganizationIdentifier ::= SEQUENCE {
> registrationSchemeIdentifier PrintableString (SIZE(3)),
> registrationCountry PrintableString (SIZE(2)),
> registrationStateOrProvince [0] IMPLICIT PrintableString OPTIONAL (SIZE(0..128)),
> registrationReference UTF8String
> }
>
> where the subfields and have the same meanings and restrictions described in Section 9.2.8.
> The CA SHALL validate the contents using the requirements in Section 9.2.8."
>
> Add new Appendix H - Registration Schemes
>
> "The following Registration Schemes are currently recognised as valid under these
> guidelines:
>
> **NTR**: The information carried in this field shall be the same as held in Subject
> Registration Number Field as specified in 9.2.5 and the country code used in
> the Registration Scheme identifier shall match that of the subject’s jurisdiction
> as specified in Section 9.2.4.
>
> Where the Subject Jurisdiction of Incorporation or Registration Field in 9.2.4
>
> includes more than the country code, the additional locality information shall
>
> be included as specified in sections 9.2.8 and/or 9.8.1.
>
> **VAT**: Reference allocated by the national tax authorities to a Legal Entity. This
> information shall be validated using information provided by the national tax
> authority against the organisation as identified by the Subject Organization
> Name Field (see 9.2.1) and Subject Registration Number Field (see 9.2.5) within
> the context of the subject’s jurisdiction as specified in Section 9.2.4.
>
> **PSD**: Authorization number as specified in ETSI TS 119 495 clause 4.4 allocated to a
> payment service provider and containing the information as specified in
> ETSI TS 119 495 clause 5.2.1. This information SHALL be obtained directly from the
> national competent authority register for payment services or from an information
> source approved by a government agency, regulatory body, or legislation for this
> purpose. This information SHALL be validated by being matched directly or indirectly
> (for example, by matching a globally unique registration number) against the
> organisation as identified by the Subject Organization Name Field (see 9.2.1) and
> Subject Registration Number Field (see 9.2.5) within the context of the subject’s
> jurisdiction as specified in Section 9.2.4. The stated address of the organisation
> combined with the organization name SHALL NOT be the only information used to
> disambiguate the organisation."
>
> ---MOTION ENDS---
>
> *** WARNING ***: USE AT YOUR OWN RISK. THE REDLINE BELOW IS NOT THE OFFICIAL VERSION
> OF THE CHANGES (CABF Bylaws, Section 2.4(a)):
>
> A comparison of the changes can be found at:
>
> https://github.com/cabforum/documents/compare/Ballot-SC17---Alternative-registration-numbers-for-EV-certificates?diff=unified&expand=1
>
> Changes since version 5:
>
> 1. Remove Registration Reference Provider.
> 2. Note that Registration References MAY contain hyphens, and clarify that the first hyphen is the separator.
> 3. Fix cross-references in Appendix H.
>
> A comparison of the changes since version 5:
>
> https://github.com/cabforum/documents/compare/28764a1..a29069d
>
> The procedure for approval of this ballot is as follows:
> Discussion (7+ days)
> Start Time: May 6, 2019 4:00pm Eastern
> End Time: May 13, 2019 4:15pm Eastern
> Vote for approval (7 days)
> Start Time: May 13, 2019 4:15pm Eastern
> End Time: May 20, 2019 4:15pm Eastern
> _______________________________________________
> Servercert-wg mailing list
> Servercert-wg at cabforum.org
> http://cabforum.org/mailman/listinfo/servercert-wg
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