[cabf_validation] Proposed ballot on improving Registration Number language in EVGs

Wed Aug 28 20:57:06 UTC 2024

That’s a fair point, and thank you for the additional discussion. There is in fact a large grey area between black and white, as there usually is.

The reason this one crossed the line into a normative requirement for me was largely because it defined a Date of Formation, and then was talking about how that date should be formatted (which requires usage and context), which I personally think is clearly outside the boundaries of what a Date of Formation *is*.

The  gray area is exactly where you describe, where there can be disagreements about what is an essential property of a thing, and what are requirements around a thing. For example, if you had written:

Date of Formation: A ten character string that specifies the date where a Legal Entity was first recognized by the jurisdiction in which it was created or formed, in the form of a complete representation of an extended format calendar date (“YYYY-MM-DD”) in ISO 8601.

Then that clearly defines a thing. I don’t like defining it that way, but it works. We’re now defining a string, and characterizing its contents independently of any requirements of how it gets used. The definition is self-contained and the world is good again. Sort of.

Forward and up,

-Tim

From: Clint Wilson <clintw at apple.com> 
Sent: Wednesday, August 28, 2024 4:25 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com>
Cc: CABforum3 <validation at cabforum.org>; Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>
Subject: Re: [cabf_validation] Proposed ballot on improving Registration Number language in EVGs

This is helpful. 

To be clear, I agree that normative requirements should be avoided in definitions, however based on your response to this proposed definition change, it’s also clear there’s some difference of opinion on what counts as (or doesn’t) a normative requirement. For example, what sections of the (T/S/CS)BRs constitute the body of the document? Is it just Section 1.6 that should be void of normative requirements? Should normative requirements be pulled out of Section 1 entirely? Since we don’t introduce RFC 2119 language until Section 1.6.4, does that mean all uses of those terms in prior sections are incorrect in some way? How would such a shift impact maintainability of the document, for example in a scenario where a defined term has its requirements pulled into a separate section, but then a later usage of that term doesn’t remember to include these “extra” properties of the term as used in a specific section?

When I think of a definition, I assume two basic components: the term being defined and the exact meaning of a word, including the properties, attributes, or characteristics that term and meaning encompass. For example, I don’t see the definition of Random Value as containing normative requirements; rather, it’s describing that in order for a random value to be a random value, it needs to exhibit 112 bits of entropy. Is there a “MUST” implied in the requirement that the Reliable Method of Communication be verified by the CA? Should Wildcard Domain Name not specify the unicode character codes of the defined characters?

When I think about pulling normative requirements out of definitions, I’m thinking more of terms like Request Token (because it does clearly espouse sets of interacting requirements and options) and Authorization Domain Name (because the concept is complex enough to warrant expansion in the context of its use rather than solely within the definition). 

My suggestion of including the format in the definition for Date of Formation was intended to convey that this formatting is an intrinsic property of the thing being defined. Moving that down into the profile section is completely acceptable to me. The related suggestion that this property of the defined term is a requirement that can't be included in a definition has me confused about the actual expected outcome to the content, organization, and accessibility of the BRs if that statement is applied at face value.

Cheers,

-Clint

On Aug 27, 2024, at 9:58 AM, Tim Hollebeek <tim.hollebeek at digicert.com <mailto:tim.hollebeek at digicert.com> > wrote:

My opinion is that all requirements need to be stated in RFC 2119 language and be present in the body of the document in order to be treated as normative requirements. That should be an uncontroversial view. I suspect our auditor friends have a similar view. I don’t think it’s a particularly hard line or strict view, it’s just what’s necessary to prevent ambiguity as to what the requirements are.

I would be fine with once in the section. Something along the lines of “The Date of Formation MUST be formatted according to the complete representation of an extended format calendar date in ISO 8601 (i.e. YYYY-MM-DD; e.g. 0001-01-01).”

-Tim

From: Clint Wilson <clintw at apple.com <mailto:clintw at apple.com> > 
Sent: Tuesday, August 27, 2024 9:06 AM
To: Tim Hollebeek <tim.hollebeek at digicert.com <mailto:tim.hollebeek at digicert.com> >; CABforum3 <validation at cabforum.org <mailto:validation at cabforum.org> >
Cc: Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr <mailto:dzacharo at harica.gr> >
Subject: Re: [cabf_validation] Proposed ballot on improving Registration Number language in EVGs

Hi Tim,

I think including the format of this specific date type in the definition is totally reasonable, given that it’s not applicable to any other date types and so can very much exist intrinsically as part of the definition. That is, I don’t agree with the seemingly hard line you’re drawing in your statement — and, even moreso, I don’t believe such a statement is backed by consensus within the Forum so I also don’t want it construed as more than your opinion, as indeed is my above statement that it can be part of the definition.

All that said, I do agree putting it in-line in the EVGs would work just fine too. Are you then imagining we would repeat this format requirement alongside each of the four times the term is used in 7.1.4.2.5 or just state it once somewhere in that section? Do you have some example text you can provide to show what you’re proposing as an alternative approach?

Thank you,

-Clint

On Aug 26, 2024, at 10:32 AM, Tim Hollebeek via Validation <validation at cabforum.org <mailto:validation at cabforum.org> > wrote:

This is a requirement, and any requirements around how dates should be formatted need to be stated as such in the appropriate profile section. It MUST NOT be stated in the definition.

-Tim

From: Validation <validation-bounces at cabforum.org <mailto:validation-bounces at cabforum.org> > On Behalf Of Dimitris Zacharopoulos (HARICA) via Validation
Sent: Friday, August 23, 2024 2:26 AM
To: CABforum3 <validation at cabforum.org <mailto:validation at cabforum.org> >
Subject: Re: [cabf_validation] Proposed ballot on improving Registration Number language in EVGs

On 16/8/2024 2:53 π.μ., Clint Wilson via Validation wrote:

Hi Corey, 

Overall this seems like a good improvement to clarity of the current expectations related to these sections of the EVGs, reflecting the predominant approach to populating the subject:serialNumber field for EV TLS certificates. I do think it would be valuable to standardize on a date format (admittedly somewhat because it feels like a missed opportunity to not do so). What about something like modifying the newly added definition:

**Date of Formation**: The date on which a Legal Entity is first recognized by the jurisdiction in which it was created or formed. The date is formatted according to the complete representation of an extended format calendar date in ISO 8601 (i.e. YYYY-MM-DD; e.g. 0001-01-01).

Hi Clint,

I'm in favor of examples where they help avoid unintended mistakes, so I would support adding something like "e.g. 2000-12-31" to make it abundantly clear where the month and day is supposed to be represented.

Thanks,
Dimitris.

The parenthetical is probably too much, but you get the idea. And then the three instances of "in any one of the common date formats” could just be deleted.

Cheers,

-Clint

On Aug 9, 2024, at 8:55 AM, Corey Bonnell via Validation  <mailto:validation at cabforum.org> <validation at cabforum.org>wrote:

Hello,

Some time ago, I presented [1] a ballot proposal on improving the requirements for the Registration Number value in the EVGs. Here is the current proposal:  <https://github.com/cabforum/servercert/compare/main...CBonnell:servercert:govt-entity-serial-number> https://github.com/cabforum/servercert/compare/main...CBonnell:servercert:govt-entity-serial-number.

On the call where the proposal was presented, there was a desire to explore standardizing date formats for the Date of Formation. Is this something that we would like to see added to the ballot? For the sake of minimizing scope of the ballot, I’m in favor of moving forward without such a requirement, but will certainly be happy to incorporate if there are strong feelings that such a requirement should be added in this ballot.

Thanks,

Corey

[1]  <https://lists.cabforum.org/pipermail/validation/2024-July/001997.html> https://lists.cabforum.org/pipermail/validation/2024-July/001997.html

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