[cabf_validation] OrganisationIdentifier mandated by ETSI TS 119 495

Adriano Santoni adriano.santoni at staff.aruba.it
Tue Nov 6 00:28:35 MST 2018


Hi Moudrick,

Article 34 of COMMISSION DELEGATED REGULATION (EU) 2018/389 of 27 
November 2017 reads:

"For the purpose of identification, as referred to in Article 30(1)(a), 
payment service providers *shall *rely on qualified certificates"

I do not think that this wording allows using non qualified certs, but 
please correct me if I am wrong.

Adriano


Il 05/11/2018 22:13, Moudrick M. Dadashov ha scritto:
> Hi Adriano,
>
> I'd say "The communication between the TPP and the ASPSP must always 
> be secured by TLS 1.2 or higher, but that doesn't mean QWACs must be 
> used" (see attached pic).
>
> M.D.
>
> On 11/5/2018 5:40 PM, Adriano Santoni via Validation wrote:
>>
>> Dimitris' description is correct.
>>
>> Just a remark on qualified certificates for electronic seals (a 
>> strange beast to all non-European CAs, I guess), since you mention 
>> them: they are not provided for as an alternative to QWACs - they are 
>> (will be) used for different purposes, that is for signing requests 
>> by the TPP (if so required by the ASPSP) at application level. But 
>> QWACs will always be required. The communication between the TPP and 
>> the ASPSP must always be secured by TLS 1.2 or higher, and in that 
>> context QWACs must be used. At least, this is my understanding, based 
>> on presentations and papers that I am aware of. The ETSI people 
>> involved in Open Banking standardization may correct me if I am wrong.
>>
>> Adriano
>>
>>
>> Il 05/11/2018 15:40, Dimitris Zacharopoulos (HARICA) via Validation 
>> ha scritto:
>>> On 5/11/2018 11:56 πμ, Ryan Sleevi via Validation wrote:
>>>>
>>>>
>>>> On Mon, Nov 5, 2018 at 4:38 AM Adriano Santoni via Validation 
>>>> <validation at cabforum.org <mailto:validation at cabforum.org>> wrote:
>>>>
>>>>     Just to provide a wider picture of the implications (to those
>>>>     who are interested in this topic):
>>>>
>>>>     Not only is the organizationIdentifier attribute required by
>>>>     ETSI TS 119 495 (*): its presence in the QWAC certificate is
>>>>     also taken for granted by the "Implementation Guidelines"
>>>>     published by the Berlin Group
>>>>     (https://www.berlin-group.org/nextgenpsd2-downloads). And I
>>>>     suppose that several major banks and other fintech companies
>>>>     are currently developing and/or integrating APIs based on those
>>>>     guidelines.
>>>>
>>>>     So... it looks like a time bomb.
>>>>
>>>>     Adriano
>>>>
>>>>     (*) Which, to my understanding, technically implements the
>>>>     requirements of Art. 34 of the COMMISSION DELEGATED REGULATION
>>>>     (EU) 2018/389 of 27 November 2017.
>>>>
>>>> It seems like participating CA members can flag the profile 
>>>> incompatibilities. As I mentioned, there's nothing inherent in the 
>>>> profile that requires the use of publicly-trusted QWACs - where 
>>>> there exists profile incompatibilities between multiple technical 
>>>> profiles, it's only natural to recognize you can only correctly 
>>>> implement one of the profiles. Given that qualified certificates 
>>>> have their legal value independent of the trust status of those 
>>>> certificates, and given that PSD2 specifies such a profile for the 
>>>> purpose of legal value, it seems the value can be recognized for 
>>>> such server-to-server exchanges without the necessity for a change 
>>>> in the BRs or EVGs. Indeed, as the SHA-1 issue in the payment 
>>>> services industry has profoundly demonstrated, the use of separate 
>>>> hierarchies for such payment processing certificates can be a boon 
>>>> to the system, as such terminals may not be able to handle the 
>>>> "rapid" change of the public trust ecosystem.
>>>>
>>>
>>> Does this only affect Banks in EU or does it also affect credit-card 
>>> merchants in EU? If it includes credit-card merchants, then we have 
>>> a significantly greater number of organizations that will soon be 
>>> requesting such certificates (mandated by a legal requirement) that 
>>> contains this particular information both in the SubjectDN and the 
>>> qcStatements that includes the "role" of the Subscriber (PSP_AS, 
>>> PSP_PI, PSP_AI or PSP_IC).
>>>
>>> Although the implementing act also accepts Qualified electronic 
>>> seals, shouldn't the Forum try to accommodate the QWAC solution as well?
>>>
>>> I hate to bring this argument in the discussion but, at least 
>>> according to the BRs (9.16.3), the Forum is supposed to try to 
>>> modify the requirements to make it possible for CAs to comply with 
>>> both the Requirements and the Law simultaneously. EV Guidelines 
>>> describe it a little differently in section 8.1.
>>>
>>> Setting aside the technical effectiveness of the proposed syntax and 
>>> whether this information should be broken in more than one fields or 
>>> not, under the scheme of ETSI EN 319 412-3, all Legal Entities can 
>>> have an /organizationIdentifier /which can be used as an "improved 
>>> version" of the /serialNumber/, which currently has no semantics as 
>>> recently demonstrated by Daymion at the Shanghai F2F. Why can't we 
>>> define it properly and use it for all legal entities in EV, 
>>> regardless of the PSD2 directive?
>>>
>>> I would like people to consider Wayne's proposals 2 and 3 at the 
>>> London F2F 
>>> <https://cabforum.org/2018/06/06/minutes-for-ca-browser-forum-f2f-meeting-44-london-6-7-june-2018/#Subject-information-in-EV-certificates-specified-in-clause-92-of-the-EV-Guidelines-and-whether-this-allows-for-the-inclusion-of-X520-organizationIdentifier>.
>>>
>>> "Wayne: Seems to reserve this field for ETSI use only. Two ways 
>>> forward: no, you can’t use this field at all (status quo), or 
>>> reserve it for ETSI and make sure it is extensible, or reserve it 
>>> for ETSI and revisit guidelines when/if another request comes along".
>>>
>>> This is what ETSI suggests in the existing technical documents:
>>>
>>> From ETSI EN 319 412-3: "The /organizationIdentifier /attribute 
>>> shall contain an identification of the subject organization 
>>> different from the organization name. Certificates may include one 
>>> or more semantics identifiers as specified in clause 5 of ETSI EN 
>>> 319 412-1".
>>>
>>> This means that, if a CA wants to use the /organizationIdentifier 
>>> /attribute with no semantics, (similar to what we have today for the 
>>> /serialNumber /attribute), they can do that just fine and add 
>>> entries like "123456789", "SN:123456789". However, if the CA wants 
>>> to use specific semantics as defined in ETSI EN 319 412-1, then the 
>>> /organizationIdentifier/ must have the following format:
>>>
>>> From section 5.1.4 of ETSI EN 319 412-1: "The semantics of 
>>> /id-etsi-qcs-SemanticsId-Legal/ shall be as follows.
>>> When the legal person semantics identifier is included, any present 
>>> /organizationIdentifier /attribute in the subject field shall 
>>> contain information using the following structure in the presented 
>>> order:
>>>
>>>   * 3 character legal person identity type reference;
>>>   * 2 character ISO 3166 [2] country code;
>>>   * hyphen-minus "-" (0x2D (ASCII), U+002D (UTF-8)); and
>>>   * identifier (according to country and identity type reference).
>>>
>>> The three initial characters shall have one of the following defined 
>>> values:
>>> 1) "VAT" for identification based on a national value added tax 
>>> identification number.
>>> 2) "NTR" for identification based on an identifier from a national 
>>> trade register. Or
>>> 3) Two characters according to local definition within the specified 
>>> country and name registration authority, identifying a national 
>>> scheme that is considered appropriate for national and European 
>>> level, followed by the character ":" (colon).
>>>
>>> Other initial character sequences are reserved for future amendments 
>>> of the present document. In case "VAT" legal person identity type 
>>> reference is used in combination with the "EU" transnational country 
>>> code, the identifier value should comply with Council Directive 
>>> 2006/112/EC [i.12] article 215. EXAMPLES: "VATBE-0876866142" and 
>>> "EI:SE-5567971433".
>>> When a locally defined identity type reference is provided (two 
>>> characters followed by ":"), the nameRegistrationAuthorities element 
>>> of SemanticsInformation (IETF RFC 3739 [1]) shall be present and 
>>> shall contain at least a uniformResourceIdentifier generalName. The 
>>> two letter identity type reference following the ":" character shall 
>>> be unique within the context of the specified 
>>> uniformResourceIdentifier."
>>>
>>> This document was extended via ETSI TS 119 495 (check section 5.2.1 
>>> of ETSI TS 119 495).
>>>
>>> This means that when a CA uses this representation of values in the 
>>> /organizationIdentifier /attribute and asserts compliance with 
>>> /id-etsi-qcs-SemanticsId-Legal/, then this is reflected in the 
>>> qcStatements extension as described in section 5.2.1 of ETSI EN 319 
>>> 412-1.
>>>
>>> Is it complicated? Of course it is. I kindly ask other members 
>>> working with these ETSI standards to please correct me if I didn't 
>>> describe the above information very accurately.
>>>
>>>
>>> Thanks,
>>> Dimitris.
>>>
>>>>
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>>
>>
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