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I believe we discussed this at the CA/B Forum meeting in Cupertino
where it was explained that an RA can be audited with the existing
ETSI/WebTrust criteria by only listing the necessary criteria
relevant to RA operations. So, for the ETSI example, an RA would be
audited against ETSI EN 319 411-1 by listing the most of the
requirements of 319 401 and the relevant sections of 411-1 for RA
operations. This scope would be clearly indicated in the attestation
letter, allowing the CA to have an independent auditor's opinion of
the RA operations of a delegated third party.<br>
<br>
I believe WebTrust for RAs has made a great job of defining the
relevant criteria and separating them in a different document. ETSI
has done something similar by identifying "service components" in EN
319 411-1 (OVR, REG, REV, DIS, and so on).<br>
<br>
<br>
Dimitris.<br>
<br>
<div class="moz-cite-prefix">On 18/6/2019 8:51 μ.μ., Ryan Sleevi via
Public wrote:<br>
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<div dir="ltr" class="gmail_attr">On Tue, Jun 18, 2019 at 1:35
PM Jeremy Rowley via Public <<a
href="mailto:public@cabforum.org" moz-do-not-send="true">public@cabforum.org</a>>
wrote:<br>
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<p class="MsoNormal">I think I heard the WebTrust
auditors say last week that they have finished or
nearly finished the WebTrust for RAs criteria. The
language from Section 8.4 of the guidelines reads:</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">“For Delegated Third Parties which
are not Enterprise RAs,, then the CA SHALL obtain an
audit report, issued under the auditing standards that
underlie the accepted audit schemes found in Section
8.1, that provides an opinion whether the Delegated
Third Party’s performance complies with either the
Delegated Third Party’s practice statement or the CA’s
Certificate Policy and/or Certification Practice
Statement. If the opinion is that the Delegated Third
Party does not comply, then the CA SHALL not allow the
Delegated Third Party to continue performing delegated
functions.”</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">We know some CAs use RAs that are
not audited under WebTrust/ETSI because “there is no
appropriate audit standard”. Now that there is an
audit standards, it seems to me this criteria goes
into effect immediately and any RA not audited would
cause the CA to be out of compliance with the BRs. No
additional ballot required since the concept is
already baked into the BRs. </p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Anyone have a different
interpretation? If not, when is the exact date that
the audits should be done? Already?</p>
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<div>TL;DR: Don't worry. I don't think there's an impending
doom date.</div>
<div><br>
</div>
<div>Officially, Chrome is not planning to immediately enforce
the WebTrust for RAs audit, and is still evaluating the most
effective means to use and consume this.</div>
<div><br>
</div>
<div>For best results, however, don't use RAs ;)</div>
<div><br>
</div>
<div>Here's the alternative interpretation I'll over you:<br>
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<div>The "auditing standards that underlie the accepted audit
criteria" are, in the case of WebTrust, are SSAE 18 (US),
CSAE 3000 - 3001 (CA), and ISAE 3000 (elsewhere), with
potentially jurisidiction-specific (self-?)regulatory
requirements or modifications, similar to the US/CA
harmonization with IFAC.</div>
<div><br>
</div>
<div>The "auditing standards that underlie the accepted audit
criteria" are, for ETSI EN 319 411-1 and ETSI EN 319 403,
either (depending on your perspective of "standard"), going
to be seen as:</div>
<div> a) ETSI EN 319 411-1 / ETSI EN 319 403</div>
<div> b) ISO/IEC 17065</div>
<div><br>
</div>
<div>The former takes the view that the ETSI ESI documents are
themselves the standards for auditing, in that they define a
set of standards appropriate for "an" audit scheme, although
absent the eIDAS Regulation lacks any normative guidance
about who the defining authority is for the appropriate
auditor (compared to IFAC and its constituent organizations,
which does).</div>
<div><br>
</div>
<div>The latter takes the view that the ETSI ESI documents are
themselves adopted from the ISO/IEC standards and guidance
on the development of certification schemes (which covers a
broad scheme of activities), and that any scheme derived
from the principles of 17065 is suitably empowered. It,
similarly, lacks the guidance as to who can perform the
assessments, since that is the role of the scheme operator
(e.g. EU in the case of eIDAS)</div>
<div><br>
</div>
<div>The "nice" thing about these interpretations is that for
CAs that are concerned about being beyond reproach, but
still make the (unfortunate) choice to make use of delegated
third parties, they can read these requirements as using the
relevant criteria from WebTrust or ETSI, under the existing
supervisory scheme, and argue compliance. CAs that don't
like to/don't want to know what their RAs are doing, and
aren't as concerned about security, could reasonably argue
that the applicability of the underlying standard means the
CA defines what the expectations are (for example, an
"Agreed Upon Procedures" report - which I'm sure Don and
Jeff will jump in mentioning the CSAE limitations there),
and then allow 'anyone' to perform that audit, modulo the
IFAC standards with respect to professional licensure.</div>
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