[Servercert-wg] Ballot SC17 version 3: Alternative registration numbers for EU certificates
Erwann Abalea
Erwann.Abalea at docusign.com
Fri Apr 5 12:02:20 MST 2019
Bonsoir,
I wrote some comments in the Github flow, but I’ll repeat them below.
Is the proposal really adding 2 new clauses, 9.2.8 and 9.2.9 with the same exact title « Subject Organization Identifier Field » ? Reading the text, I think that 9.2.8 goal is trying to explain the content of the organizationIdentifier attribute, while 9.2.9 goal is to define an extension (which is a different beast).
Under 9.2.8, the subdivision is arbitrarily set to be 2 characters long. In ISO 3166-2, some codes are shorter or longer than 2 characters. I haven’t bought the standard yet, so I don’t know if there’s a size constraint defined.
If 9.2.9 is an extension, let me propose a rephrase of the definition, adjust accordingly (uppercase/lowercase initials are important in ASN.1) :
id-euPSD2AuthorizationNumber OBJECT IDENTIFIER ::= { joint-iso-itu-t(2) international-organizations(23) ca-browser-forum(140)
certificate-extensions(3) eu-psd2-authorization-number(1) }
ext-euPSD2AuthorizationNumber EXTENSION ::= { SYNTAX EUPSD2AuthorizationNumber IDENTITIED BY id-euPSD2AuthorizationNumber }
EUPSD2AuthorizationNumber ::= SEQUENCE {
registrationSchemeIdentifier PrintableString,
registrationCountry PrintableString,
registrationStateorProvince PrintableString OPTIONAL,
registrationReference PrintableString
}
I’d be tempted to change at least the PrintableString for registrationReference into something that allows a larger character set. X.520 defines the organizationIdentifier as a DirectoryString, thus allowing UTF8. PrintableString is fine for a country code, probably for a scheme identifier, but I don’t see any reason to fix in stone right now what characters are registries allowed to use in states/provinces codes (ISO3166-2) or registration identifiers.
Pleade also add that this extension MUST NOT be critical.
Cordialement,
Erwann Abalea
De : Servercert-wg <servercert-wg-bounces at cabforum.org> au nom de Tim Hollebeek via Servercert-wg <servercert-wg at cabforum.org>
Répondre à : Tim Hollebeek <tim.hollebeek at digicert.com>, CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org>
Date : vendredi 5 avril 2019 à 15:23
À : CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org>
Objet : [Servercert-wg] Ballot SC17 version 3: Alternative registration numbers for EU certificates
Just posting a “new” version to refresh the discussion period timer.
I’ll have more comments later today after I’m done catching up with all the email I got while I was gone …
-Tim
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Ballot SC17: Alternative registration numbers for EU certificates
Purpose of Ballot: Allow for the inclusion of additional information in
certificates in order to comply with relevant EU regulations.
The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
by Dimitris Zacharopoulos of Harica and Enrico Entshew of D-Trust.
Conflicts with other ballots:
Ballot SC16 modifies EV Guidelines Section 9.2.8 and adds Section 9.2.9. The
new sections 9.2.8 and 9.2.9 from this ballot should be placed in front of the
sections from SC16 if both ballots pass, renumbering those sections as 9.2.10
and 9.2.11, and renumbering the following sections as necessary.
Motivation:
Update to CAB Forum EV Guidelines to cater for alternative registration numbers
caused by EU Legal Requirements:
i. The EU Regulation No 910/2014 (eIDAS [https://eur-lex.europa.eu/eli/reg/2014/910/oj])
defines regulatory requirements for certificates with an agreed quality level
called Qualified. This regulation specifies in Annex IV specific requirements
for “Qualified certificates for website authentication” including the
statement that the certificate shall contain: “for a legal person: the name
and, where applicable, registration number as stated in the official records,”
ii. It is understood that this requirement relates to validated attributes for
the identification of the certificate subject and hence is best fitted in the
subject’s distinguished name.
iii. In line with the regulatory framework ETSI has defined a general structure
for carrying “registration numbers” in TS 119 412-1
[https://www.etsi.org/standards-search#page=1&search=TS119412-1] clause 5.1.4.
This uses the X.520 [https://www.itu.int/rec/dologin_pub.asp?lang=e&id=T-REC-X.520-201210-S!!PDF-E&type=items]
organizationIdentifier within the subject’s distinguished name in line with its
stated purpose being “holds an identification of an organization different
from the organization name”. This is used for ETSI requirements to carry
registration numbers for certificates, Qualified or otherwise.
iv. It is considered that this use of organizationIdentifier supports the primary
purpose of EV certificates as stated in section 2.1.1 of the EV Guidelines as
“other disambiguating information”.
v. A recent EU delegated Regulation 2018/389 on secure communications for payment
services (RTS [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R0389])
states in Article 34.2 that for Qualified Website certificates (QWACs) the
registration number required in eIDAS “shall be the authorisation number of the
payment service provider … or equivalent [reference made to earlier regulations
relating to banks]”.
vi. ETSI has specified TS 119 495
[https://www.etsi.org/standards-search#page=1&search=TS119495] requirements for
carrying PSD2 related registration numbers in the general structure for
registration numbers defined in TS 119 412-1 clause 5.1.4 as mentioned in
iii. above.
vii. ETSI has endeavoured to ensure and always intended that requirements relating
to web site certificates at the Qualified level are in line with the CA/B Forum
EV Guidelines.
viii. This proposal only includes some of the Registration Schemes as used in
ETSI TS 119 412-1, which have clear validation rules (NTR, VAT, PSD) that provide
reasonable assurance in line with the EV Guidelines. The IPR for the semantics
of this scheme is proposed to be released to the CA/B Forum allowing it to
further extend the use of organizationIdentifier to include other Registration
Schemes (e.g. LEI) and corresponding validation rules, at the CA/B Forum’s
discretion. Also, any further changes by ETSI to ETSI TS 119 412-1 will not
impact the CA/B Forum.
ix. Having found out that CA/B Forum’s interpretation of EV Requirements in section
9.2.8 “Other Attributes” was not in line with those understood by ETSI experts,
ETSI would like to harmonise with CA/B Forum approach to carrying alternative
forms of registration number for PSD2 and other registration schemes.
b) CA/B Forum specific concerns are:
i. Requirements regarding Attributes to be included in the Subject DN need to be
explicitly covered in 9.2.
ii. Organisations may wish to identify OrganisationalUnits within their organisation.
It is unclear if this is currently allowed in the EV Guidelines (similar
ambiguity in section 9.2.8).
iii. There are objections to ETSI specific usage of the orgID field (no squating).
iv. The procedures for validation of the attribute need to be clearly stated.
v. There may be other uses of the organizationIdentifier field in various PKIs,
however it is not considered to be a problem. Because of the unique semantics we
are specifying for each identifier, applications should be able to understand
different uses of the OrgID field by different issuers and users. There are many
different "PKIs" out there that can use all X.500 attributes differently and with
different validation or no validation at all. To the best of our knowledge, the
WebPKI has never used this subjectDN attribute before for Publicly-Trusted
Certificates. Thus there is no "conflict" by using this attribute in the EV
Guidelines for SSL/TLS Certificates, and perhaps later for EV Code Signing
Certificates.
vi. This use of organisationIdentifier must be extendable to allow for use by other
registration numbers allocated by different registration schemes. Some CAB Forum
members have indicated interest in carrying registration numbers other than for
Incorporation within EV Certificates. This is catered for in the current proposal.
vii. There is interest by some CA/B Forum members in carrying LEIs within CA/B Forum
certificates but as yet the LEI registration scheme is not currently considered
sufficiently robust to be recognised as an registration numbering scheme to be
accepted by CA/B Forum. Therefore this proposal only introduces a limited set of
Registration Schemes (namely NTR, VAT, PSD) which have reasonably robust
validation rules.
viii. Some CA/B Forum members have indicated the possible need for multiple
identifiers in the subject name. This, however, cannot be achieved using X.520
organizationIdentifier which defined this attribute as being “SINGLE VALUE”. The
use of a single value has the advantage is it is clear what is the registration,
in addition to the company registration, which identifies the subject.
---MOTION BEGINS---
Purpose of Ballot: Update to CAB Forum EV Guidelines to allow alternative
registration numbers
Proposed Ballot for Changes to EVG 1.6.8
Add to section 4 definitions:
"Legal Entity: A Private Organization, Government Entity, Business Entity, or
Non-Commercial Entity.
Registration Reference: A unique identifier assigned to a Legal Entity.
Registration Scheme: A scheme for assigning a Registration Reference meeting the
requirements identified in Section 9.2.8."
Insert new sections 9.2.8 and 9.2.9 (renumbering following sections as necessary):
"9.2.8. Subject Organization Identifier Field
Certificate field: organizationIdentifier (OID: 2.5.4.97)
Required/Optional: Optional
Contents: If present, this field MUST contain a Registration Reference for a
Legal Entity assigned in accordance to the identified Registration Scheme.
The organizationIdentifier MUST be encoded as a PrintableString or UTF8String
(see RFC 5280).
The Registration Scheme MUST be identified using the using the following structure
in the presented order:
• 3 character Registration Scheme identifier;
• 2 character ISO 3166 country code for the nation in which the Registration
Scheme is operated, or if the scheme is operated globally ISO 3166 code
“XG” shall be used;
• hyphen-minus "-" (0x2D (ASCII), U+002D (UTF-8));
• if required under Section 9.2.5, a 2 character ISO 3166-2 identifier for the
subdivision (state or province) of the nation in which the Registration Scheme
is operated, followed by hyphen-minus "-" (0x2D (ASCII), U+002D (UTF-8)); and
• Registration Reference allocated in accordance with the identified Registration
Scheme
As in section 9.2.5, the specified location information MUST match the scope of the
registration being referenced.
Examples:
NTRGB-12345678
NTRUS-CA-12345678
VATDE-123456789
PSDBE-NBB-1234.567.890
Registration Schemes listed in Appendix H are currently recognized as valid under
these guidelines.
The CA SHALL:
a) confirm that the organization represented by the Registration Reference is the
same as the organization named in the organizationName field as specified in
Section 9.2.1 within the context of the subject’s jurisdiction as specified in
Section 9.2.5;
b) further verify the Registration Reference matches other information verified
in accordance with section 11;
c) take appropriate measures to disambiguate between different organizations as
described in Appendix H for each Registration Scheme;
d) Apply the validation rules relevant to the Registration Scheme as specified
in Appendix H.
"9.2.9. Subject Organization Identifier Field
Certificate field: euPSD2AuthorizationNumber (OID: 2.23.140.3.1)
Verbose OID: {joint-iso-itu-t(2) international-organizations(23) ca-browser-forum(140)
certificate-extensions(3) eu-psd2-authorization-number(1) }
Required/Optional: Optional
Contents: If present, this field MUST contain a Registration Reference for a
Legal Entity assigned in accordance to the identified Registration Scheme.
The Registration Scheme MUST be encoded as described by the following ASN.1 grammar:
RegistrationScheme ::= BEGIN
euPSD2AuthorizationNumber ::= SEQUENCE {
RegistrationSchemeIdentifier PrintableString,
RegistrationCountry PrintableString,
RegistrationStateorProvince PrintableString,
RegistrationReference PrintableString
}
END
where the subfields and have the same meanings and restrictions described in Section 9.2.8.
The CA SHALL validate the contents using the requirements in Section 9.2.8."
Add new Appendix H - Registration Schemes
"The following Registration Schemes are currently recognised as valid under these
guidelines:
NTR: The information carried in this field shall be the same as held in Subject
Registration Number Field as specified in 9.2.6 and the country code used in
the Registration Scheme identifier shall match that of the subject’s jurisdiction
as specified in Section 9.2.5.
VAT: Reference allocated by the national tax authorities to a Legal Entity. This
information shall be validated using information provided by the national tax
authority against the organisation as identified by the Subject Organization
Name Field (see 9.2.1) and Subject Registration Number Field (see 9.2.6) within
the context of the subject’s jurisdiction as specified in Section 9.2.5.
PSD: Authorization number as specified in ETSI TS 119 495 clause 4.4 allocated to a
payment service provider and containing the information as specified in
ETSI TS 119 495 clause 5.2.1. This information SHALL be obtained directly from the
national competent authority register for payment services or from an information
source approved by a government agency, regulatory body, or legislation for this
purpose. This information SHALL be validated by being matched directly or indirectly
(for example, by matching a globally unique registration number) against the
organisation as identified by the Subject Organization Name Field (see 9.2.1) and
Subject Registration Number Field (see 9.2.6) within the context of the subject’s
jurisdiction as specified in Section 9.2.5. The stated address of the organisation
combined with the organization name SHALL NOT be the only information used to
disambiguate the organisation.
Where the Subject Jurisdiction of Incorporation or Registration Field in 9.2.5
includes more than the country code, the Registration Number shall be preceded
by a globally recognised identifier such as defined in ISO 3166-2, representing
the same locality, state or province, followed by hyphen-minus
((0x2D (ASCII), U+002D (UTF-8))."
---MOTION ENDS---
*** WARNING ***: USE AT YOUR OWN RISK. THE REDLINE BELOW IS NOT THE OFFICIAL VERSION
OF THE CHANGES (CABF Bylaws, Section 2.4(a)):
A comparison of the changes can be found at:
https://github.com/cabforum/documents/compare/Ballot-SC17---Alternative-registration-numbers-for-EU-certificates?diff=unified&expand=1
Changes since version 2:
None.
A comparison of the changes since version 2:
No changes.
The procedure for approval of this ballot is as follows:
Discussion (7+ days)
Start Time: April 5, 2019 9:30am Eastern
End Time: Not before April 12, 2019 9:30am Eastern
Vote for approval (7 days)
Start Time: TBD
End Time: TBD
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