[Servercert-wg] Ballot SC17 version 4: Alternative registration numbers for EU certificates

Tim Hollebeek tim.hollebeek at digicert.com
Wed Apr 17 11:26:34 MST 2019

As usual, there is a changelog, and a diff from both the current EVGL and
version 3

of this ballot in the summary at the end.


If you commented on version 3, please make sure I addressed your comments

as I may have made some small errors or omissions.


I think we're pretty close.  Thanks to everyone for their hard work on
getting this done!





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

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.

new sections 9.2.8 and 9.2.9 from this ballot should be placed in front of

sections from SC16 if both ballots pass, renumbering those sections as

and 9.2.11, and renumbering the following sections as necessary.




Update to CAB Forum EV Guidelines to cater for alternative registration

caused by EU Legal Requirements:


i. The EU Regulation No 910/2014 (eIDAS

   defines regulatory requirements for certificates with an agreed quality

   called Qualified. This regulation specifies in Annex IV specific

   for "Qualified certificates for website authentication" including the 

   statement that the certificate shall contain: "for a legal person: the

   and, where applicable, registration number as stated in the official


ii. It is understood that this requirement relates to validated attributes

   the identification of the certificate subject and hence is best fitted in

   subject's distinguished name. 


iii. In line with the regulatory framework ETSI has defined a general

   for carrying "registration numbers" in TS 119 412-1 

   [https://www.etsi.org/standards-search#page=1&search=TS119412-1] clause

   This uses the X.520

   organizationIdentifier within the subject's distinguished name in line
with its 

   stated purpose being "holds an identification of an organization

   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

   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

   services (RTS

   states in Article 34.2 that for Qualified Website certificates (QWACs)

   registration number required in eIDAS "shall be the authorisation number
of the 

   payment service provider . or equivalent [reference made to earlier

   relating to banks]".


vi. ETSI has specified TS 119 495 

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

   to web site certificates at the Qualified level are in line with the CA/B

   EV Guidelines.


viii. This proposal only includes some of the Registration Schemes as used

   ETSI TS 119 412-1, which have clear validation rules (NTR, VAT, PSD) that

   reasonable assurance in line with the EV Guidelines. The IPR for the

   of this scheme is proposed to be released to the CA/B Forum allowing it

   further extend the use of organizationIdentifier to include other

   Schemes (e.g. LEI) and corresponding validation rules, at the CA/B

   discretion. Also, any further changes by ETSI to ETSI TS 119 412-1 will

   impact the CA/B Forum.


ix. Having found out that CA/B Forum's interpretation of EV Requirements in

   9.2.8 "Other Attributes" was not in line with those understood by ETSI

   ETSI would like to harmonise with CA/B Forum approach to carrying

   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

   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


iv. The procedures for validation of the attribute need to be clearly


v. There may be other uses of the organizationIdentifier field in various

   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

   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

   Certificates. Thus there is no "conflict" by using this attribute in the

   Guidelines for SSL/TLS Certificates, and perhaps later for EV Code



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


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

   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

   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

   in addition to the company registration, which identifies the subject. 




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,

   Non-Commercial Entity.


Registration Reference: A unique identifier assigned to a Legal Entity.


Registration Scheme: A scheme for assigning a Registration Reference meeting

   requirements identified in Section 9.2.8."


Insert new section 9.2.8 (renumbering following sections as necessary):


"9.2.8. Subject Organization Identifier Field


**Certificate field**: organizationIdentifier (OID:


**Required/Optional**: Optional


**Contents**: If present, this field MUST contain a Registration Reference
for a 

   Legal Entity assigned in accordance to the identified Registration


The organizationIdentifier MUST be encoded as a PrintableString or

(see RFC 5280).


The Registration Scheme MUST be identified 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;

. For NTR identifiers, if required under Section 9.2.5, a 2 character ISO

     identifier for the subdivision (state or province) of the nation in

     the Registration Scheme is operated, preceded by plus "+" (0x2B
(ASCII), U+002B (UTF-8));

. (optional) 2-8 character Registration Reference provider without country

  (A-Z uppercase only, no separator) as registrationReferenceProvider,

  by a percent "%" (0x25 (ASCII) U+0025 (UTF-8)); and

. hyphen-minus "-" (0x2D (ASCII), U+002D (UTF-8)); 

. Registration Reference allocated in accordance with the identified



As in section 9.2.5, the specified location information MUST match the scope
of the

registration being referenced.




NTRGB-12345678 (NTR scheme, Great Britain, Unique Identifier at Country
level is 12345678)

NTRUS+CA-12345678 (NTR Scheme, United States - California, Unique identifier
at State level is 12345678)

NTRJP%ABCDEF-12345678 (NTR Scheme, Japan, Registration Reference provider is
ABCDEF, Unique Identifier at Country level is 12345678)


VATDE-123456789 (VAT Scheme, Germany, Unique Identifier at Country Level is


PSDBE-NBB-1234.567.890 (PSD Scheme, Belgium, NCA's identifier is NBB,
Subject Unique Identifier assigned by the NCA is 1234.567.890)


Registration Schemes listed in Appendix H are currently recognized as valid

these guidelines.




1. confirm that the organization represented by the Registration Reference
is the 

   same as the organization named in the organizationName field as specified

   Section 9.2.1 within the context of the subject's jurisdiction as
specified in 

   Section 9.2.5;

2. further verify the Registration Reference matches other information

   in accordance with section 11; 

3. take appropriate measures to disambiguate between different organizations

   described in Appendix H for each Registration Scheme;

4. Apply the validation rules relevant to the Registration Scheme as

   in Appendix H."


Insert new section 9.8 (renumbering following sections as necessary):


"9.8. Certificate Extensions




The extensions listed in the Section 9.8 are recommended for maximum

between certificates and browsers / applications, but are not mandatory on
the CAs 

except where indicated as "Required".  CAs may use other extensions that are

listed in this Section 9.8, but are encouraged to add them to this section
by ballot 

from time to time to help increase externsion standardization across the




If a CA includes an extension in a certificate that has a Certificate field
which is 

named in this Section 9.8, the CA must follow the format specified in that

However, no extension or extension format shall be mandatory on a CA unless 

specifically stated as "Required" in the subsection that describes the


9.8.1. CA/Browser Forum Organization Identifier Field


**Extension Name**: cabfOrganizationIdentifier (OID:


**Verbose OID**: {joint-iso-itu-t(2) international-organizations(23)

              certificate-extensions(3) cabf-organization-identifier(1) }


**Required/Optional**: Optional (but see below)


**Contents**: If the subject:organizationIdentifier is present, this field
SHOULD be present.  

Effective January 31, 2020, if the subject:organizationIdentifier field is

this field MUST be present.


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


    id-CABFOrganizationIdentifier OBJECT IDENTIFIER ::= { joint-iso-itu-t(2)
international-organizations(23) ca-browser-forum(140)
certificate-extensions(3) cabf-organization-identifier(1) }


    ext-CABFOrganizationIdentifier EXTENSION ::= { SYNTAX
CABFOrganizationIdentifier IDENTIFIED BY id-CABFOrganizationIdentifier }


    CABFOrganizationIdentifier ::= SEQUENCE {

        registrationSchemeIdentifier   PrintableString (SIZE(3)),

        registrationCountry            PrintableString (SIZE(2)),

        registrationStateOrProvince    [0] IMPLICIT PrintableString OPTIONAL

        registrationReferenceProvider  PrintableString (SIZE(0..8)),

        registrationReference          UTF8String



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



**NTR**: The information carried in this field shall be the same as held in

   Registration Number Field as specified in 9.2.6 and the country code used

   the Registration Scheme identifier shall match that of the subject's

   as specified in Section 9.2.5.


   Where the Subject Jurisdiction of Incorporation or Registration Field in


   includes more than the country code, the additional locality information


   be included as specified in sections 9.2.8 and/or 9.8.1.


**VAT**: Reference allocated by the national tax authorities to a Legal
Entity. This 

   information shall be validated using information provided by the national

   authority against the organisation as identified by the Subject

   Name Field (see 9.2.1) and Subject Registration Number Field (see 9.2.6)

   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

   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

   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

   jurisdiction as specified in Section 9.2.5.  The stated address of the

   combined with the organization name SHALL NOT be the only information
used to 

   disambiguate the organisation."





OF THE CHANGES (CABF Bylaws, Section 2.4(a)):


A comparison of the changes can be found at: 




Changes since version 3:


Thanks to Arno, Dimitris, Erwann, Kirk, Nick, and Ryan for their careful
review of

version 3, resulting in these many improvements:


- Fixed formatting of new sections to match rest of section 9.2.

- Removed potentially confusing reference to RFC 5280.

- Fixed specification of NTR subdivisions to be unambiguously parseable.

- Added optional Registration Reference provider field.

- Added explanations of what the examples mean.

- Changed CA/Browser Forum organizationIdentifier to a certificate extension

  instead of a subjectDN field, to address potential concerns about software

  that doesn't properly implement RFC 5280 and may not handle new subjectDN

  fields correctly.

- Moved the certificate extension to a new section 9.8 that standardizes

  optional EV certificate extensions.

- Renamed the extension to cabfOrganizationIdentifier since it is neither

  EU-specific nor PSD2-specific.

- Added a compliance deadline of January 31, 2020.  This gives implementors

  approximately 6 months after the end of IPR review to implement, in line

  with what we usually do.  It's slightly longer to avoid the winter

- Various ASN.1 improvements suggested by Ryan and Erwann.

- Moved the paragraph about subdivisions in Appendix H to the NTR section,

  to make it more clear it is only necessary for NTR schemes and not VAT or




A comparison of the changes since version 3:




The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: April 17, 2019 2:30pm Eastern

End Time: Not before April 24, 2019 2:30pm Eastern

Vote for approval (7 days)

Start Time: TBD

End Time: TBD

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