[cabfpub] [EXTERNAL] EV 11.2.1 Private Organization registration number or date

[Geoff Keating]

> On 31 Aug 2017, at 1:21 pm, Kirk Hall via Public <public at cabforum.org> wrote:
> 
> There is a well-established legal doctrine of “Impossibility”, which excuses performance of a requirement under certain limited conditions.
>  
> https://en.wikipedia.org/wiki/Impossibility <https://en.wikipedia.org/wiki/Impossibility>
>  
> In limited cases, it seems that doctrine could apply to the BRs. 
>  
> Here, we assumed every jurisdiction would provide a registration number or date when passing the EVGL rule, but we were incorrect.  It seems that substitute performance by a CA would fulfill the spirit and purpose of the EVGL rule (where absolute compliance is impossible), which doesn’t bother me.  In the meantime, we should also amend the EVGL to allow for this case (where there is no registration number or date).

In general, for EV certificate issuance, I believe that if a certificate can’t be issued under the EV criteria, it must not be issued.  It’s expected that some organizations or entities will not be able to get an EV certificate for one reason or another, and “there is no way to uniquely identify the entity” is definitely one of those reasons.
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