[cabf_validation] Australian Validation Requirements

Wayne Thayer wthayer at mozilla.com
Wed Nov 7 11:12:01 MST 2018


Dear Mr. Germyn,

I will share my own comments on your suggestions below, and encourage other
members to respond if I've missed or misstated anything.

On Sun, Nov 4, 2018 at 5:00 AM Me via Validation <validation at cabforum.org>
wrote:

> Dear Validation Subscribers,
>
> It's come to my attention that the validation requirements for EV
> Certificates for Australia are differential, depending on the CA.
> For sole properietorships in Australia, it depends on which business
> registry they check.
> For example - sole traders on the ABR (Australian Business Reigstry)
> state the entity is the sole trader themselves. ASIC (Australian
> Securities & Investments Commission) can register business names
> attached to an ABN (Australian Business Number) and the entity does not
> exist - instead the business name exists - and the holder is the person
> (be it sole trader or otherwise).
>
> I view this as a feature of the EV Guidelines. Section 8.5 describes the
types of organizations that are eligible and is designed to support most
businesses in jurisdictions around the world, even if that means there is
some overlap that can result in the same business qualifying under multiple
entity types.

It is in my opinion that the CA/Browser validation requirements be
> changed for sole traders with business name registrations have the
> entity name as the business name. Eliminating the requirement for the
> sole traders name be added to the green bar field.
> As all sole traders operating a business online will not want their full
> name in the green bar field. Sole proprietorships in Australia are much
> for convenient for smaller businesses in Australia than forming a
> limited company that costs thousands of Australian Dollars just to form
> - not to mention the ongoing costs which makes it infeasible for small
> businesses in Australia.
>
> EV Certificates are designed to accurately represent information about the
Subscriber, so if the Subscriber is a sole proprietor the organizationName
should display their name. The EV Guidelines recognize the situation you've
described by permitting the field to also contain an assumed name, but not
to omit the true name of the business. It is unlikely that the EV
Guidelines will be changed to accommodate sole proprietorships at the
expense of providing accurate information to Relying Parties, and there are
also concerns about the ease with which a misleading assumed name can be
registered.

Thanks,

Wayne

The CA/Browser validation requirements should be changed to allow
> smaller businesses in Australia the right to have an equal oppertunity
> to big corporations in registrations of EV certificates.
>
> Sincerely,
> Drew Germyn.
>
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