[cabfpub] BR Enterprise RAs

Jeremy Rowley jeremy.rowley at digicert.com
Fri Jan 17 17:57:41 UTC 2014

Because the language comes straight from the EV Guidelines.  Maybe we should update both at the same time?


From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Ryan Sleevi
Sent: Friday, January 17, 2014 10:26 AM
To: Rich Smith
Subject: Re: [cabfpub] BR Enterprise RAs


Third or higher is insufficient for most ccTLDs (example.co.uk) or overly broad for gTLDs (foo.example).

Is there a reason you didn't simply refer to the registered domain name (and any preceding labels)?

That also covers the school.k12.wv.us type registrations as well.

On Jan 17, 2014 9:19 AM, "Rich Smith" <richard.smith at comodo.com> wrote:


In reviewing internal practices and BR compliance, we have discovered that the BRs seem to have a more restricted definition of what an Enterprise RA is allowed than the EV Guidelines.  I think this is due simply to the wording of the BRs rather than specific intent.  Because of that, I would like to propose the following amendment to the BRs.  Please review and let me know if you are willing to endorse.


----Motion Begins----



14.2.4      Enterprise RAs

The CA MAY designate an Enterprise RA to verify certificate requests from the Enterprise RA’s own organization.

The CA SHALL NOT accept certificate requests authorized by an Enterprise RA unless the following requirements are satisfied:

1.    The CA SHALL confirm that the requested Fully-Qualified Domain Name(s) are within the Enterprise RA’s verified Domain Namespace (see Section 7.1.2 para 1).


With the following:

14.2.4      Enterprise RAs

The CA MAY contractually authorize the Subject of a specified Valid Certificate to perform the RA function and authorize the CA to issue additional Certificates at third and higher domain levels that are contained within the domain of the original Certificate (also known as an Enterprise Certificate).  In such case, the Subject SHALL be considered an Enterprise RA, and the following requirements SHALL apply:

(1)   An Enterprise RA SHALL NOT authorize the CA to issue an Enterprise Certificate at the third or higher domain levels to any Subject other than the Enterprise RA or a business that is owned or directly controlled by the Enterprise RA;

(2)   In all cases, IF the Enterprise Certificate is to contain Organization details, the Subject of an Enterprise Certificate MUST be an organization verified by the CA in accordance with these Requirements; 

(3)   The CA MUST impose these limitations as a contractual requirement with the Enterprise RA and monitor compliance by the Enterprise RA; and,

(4)   The audit requirements of Section 17.1 of these Requirements SHALL apply to the Enterprise RA, except in the case where the CA maintains control over the Root CA Private Key or Subordinate CA Private Key used to issue the Enterprise Certificates, in which case, the Enterprise RA MAY be exempted from the audit requirements.  In the case that the Enterprise RA is granted a Technically Constrained Subordinate CA Key, Section 17.9 of these audit requirements shall apply to the Enterprise RA.





Rich Smith

Validation Manager


http://www.comodo.com <http://www.comodo.com/> 



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