[cabf_validation] [EXTERNAL]Re: Proposed draft Ballot 225 to strengthen EVGL 11.6 - Operational Existence

Ryan Sleevi sleevi at google.com
Wed May 23 13:11:38 MST 2018

I'm not sure that it certainly wouldn't make sense, and that's why I'm
trying to unpack.

The implicit statement of this ballot is that the existing methods of
verifying existence are insufficient. It then poses to change that, with
something that doesn't work across jurisdictional boundaries - as
rightfully pointed out. This means that there's going to be some degree of
interpretation, by CAs, as to whether or not a given jurisdiction meets
those requirements. Doesn't it make sense to normalize that interpretation?

That is, if we're rejecting a globally applicable situation, on the basis
of jurisdictional grounds, and expect to have per-jurisdiction exceptions,
then for the benefit of consistency, we should express these as
per-jurisdiction rules, rather than as general rules (subject to
interpretation) and exceptions.

I think the outcome is similar to what you pose: which is "Here's a method
for validating operational existence using financial information", and then
listing all the jurisdictions and countries that such a method is
applicable to. Then you also list "Here's a method for validating
operational existence using a pinky-swear", and then listing all the
jurisdictions and countries in which pinky-swears are legally binding and

What doesn't seem to make sense is "Here's the method for validating
operational existence", which then only describes financial information (or
pinky-swears), and then says "And if you can't do this, but you're in X, Y,
and Z, you can use pinky swears instead".

On Wed, May 23, 2018 at 3:01 PM, Tim Hollebeek <tim.hollebeek at digicert.com>

> Well, it certainly wouldn’t make sense to explicitly list the countries
> where EV issuance is permitted.  We should layer improvements atop the
> existing rules, to avoid undue impact on existing EV certificates in
> existing browsers.  Browsers can do what they want with information like
> “this certificate is an EV certificate, with the following validation
> enhancements that are appropriate for an allowed for the corresponding
> country code.”  Though to keep complexity down, it’s probably better to
> have a simpler model where we have something like “here are the 2019
> identity validation goals for a defined security level, and here’s the 2019
> validation rules for the US for that level.”
> For the specific case of tax rules, we could do the same thing, especially
> in cases where the tax rules differ enough to have a tangible impact on the
> quality of the validation, but financial stuff tends to be an area where
> the world is a bit more homogeneous, for obvious practical reasons.
> Likewise, for others of these as well, there are certain cases and large
> portions of the world that are homogeneous enough that a general rules will
> work.  “Here’s how you validate operational existence using financial
> information for a country in the eurozone” might make sense as an example.
> -Tim
> *From:* Ryan Sleevi [mailto:sleevi at google.com]
> *Sent:* Wednesday, May 23, 2018 12:52 PM
> *To:* Tim Hollebeek <tim.hollebeek at digicert.com>; CA/Browser Forum
> Validation WG List <validation at cabforum.org>
> *Subject:* Re: [cabf_validation] [EXTERNAL]Re: Proposed draft Ballot 225
> to strengthen EVGL 11.6 - Operational Existence
> Should that same logic apply for those with such tax authorities?
> That is, wouldn't it make sense to explicitly list the countries where EV
> issuance is permitted, according to these rules? That would certainly make
> it far easier to note which countries are permitted to obtain EV
> certificates, and what methods for each country are acceptable for that
> validation, on a country-by-country basis. This uniformity in approach
> would make it easier to avoid misinterpretation about whether or not a
> given jurisdiction meets the requirements posed.
> On Wed, May 23, 2018 at 12:35 PM, Tim Hollebeek via Validation <
> validation at cabforum.org> wrote:
> I’ve supported this for a long time. As much as I hate country-by-country
> rules, I don’t think jurisdiction-neutral validation requirements can
> always be written for requirements like this.  The world’s legal systems
> are just too diverse.  I think even with very good rules, country-specific
> exceptions are inevitable.
> We had similar issues with questions of simple geography, which don’t have
> uniform global understandings.
> -Tim
> I’d suggest this:  Let CAs who operate in other countries propose future
> amendments to EVGL 11.6 on a country-by-country basis, with reasons (e.g.,
> “we can’t do those checks here because…”) and with a proposal for an
> alternative method for verifying an Applicant’s “operational existence” in
> that country, with facts and evidence.  The Forum can then review adopt
> those proposals on a country-by-country basis – limited to Applicants in
> those countries only – and add them in an Appendix to the EVGL.  This can
> grow over time as needed.
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