[Servercert-wg] Voting Begins: Ballot SC17 version 7: Alternative registration numbers for EV certificates

Mads Egil Henriksveen Mads.Henriksveen at buypass.no
Wed May 15 22:15:24 MST 2019

Buypass votes YES to ballot SC 17 version 7.



From: Servercert-wg <servercert-wg-bounces at cabforum.org> On Behalf Of Tim Hollebeek via Servercert-wg
Sent: mandag 13. mai 2019 22:17
To: CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org>
Subject: [Servercert-wg] Voting Begins: Ballot SC17 version 7: Alternative registration numbers for EV certificates

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.


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 squatting).

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


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.


Purpose of Ballot: Update to CAB Forum EV Guidelines to allow alternative

   registration numbers

Proposed Ballot for Changes to EVG 1.6.9

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 Appendix H."

Retitle Section 9.2 as "Subject Distinguished Name Fields".

Remove Section 9.2.2 and renumber sections 9.2.3 through 9.2.8 to 9.2.2 through 9.2.7.

Insert new section 9.2.8:

"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 Scheme.

The organizationIdentifier MUST be encoded as a PrintableString or UTF8String

(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 the NTR Registration Scheme identifier, if required under Section 9.2.4, a two

  character ISO 3166-2 identifier for the subdivision (state or province) of the nation

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

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

* Registration Reference allocated in accordance with the identified Registration Scheme

Note: Registration References MAY contain hyphens, but Registration Schemes, ISO 3166

  country codes, and ISO 3166-2 identifiers do not.  Therefore if more than one hyphen

  appears in the structure, the leftmost hyphen is a separator, and the remaining hyphens

  are part of the Registration Reference.

As in section 9.2.4, 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)

* VATDE-123456789 (VAT Scheme, Germany, Unique Identifier at Country Level is 12345678)

* 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 under

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 in

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

   Section 9.2.4;

2. further verify the Registration Reference matches other information verified

   in accordance with section 11;

3. take appropriate measures to disambiguate between different organizations as

   described in Appendix H for each Registration Scheme;

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

   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 interoperability

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

except where indicated as "Required".  CAs may use other extensions that are not

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

from time to time to help increase extension standardization across the industry.

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 subjection.

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

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

9.8.1. Subject Alternative Name Extension

**Certificate field:**  _subjectAltName:dNSName_

**Required/Optional:**  Required

**Contents:** This extension MUST contain one or more host Domain Name(s) owned or controlled

by the Subject and to be associated with the Subject's server.  Such server MAY be owned and

operated by the Subject or another entity (e.g., a hosting service).  Wildcard certificates

are not allowed for EV Certificates.

9.8.2. CA/Browser Forum Organization Identifier Field

**Extension Name**: _cabfOrganizationIdentifier_ (OID:

**Verbose OID**: {joint-iso-itu-t(2) international-organizations(23) ca-browser-forum(140)

              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 present,

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 grammar:

    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 (SIZE(0..128)),

        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 these


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

   Registration Number Field as specified in 9.2.5 and the country code used in

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

   as specified in Section 9.2.4.

   Where the Subject Jurisdiction of Incorporation or Registration Field in 9.2.4

   includes more than the country code, the additional locality information shall

   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 tax

   authority against the organisation as identified by the Subject Organization

   Name Field (see 9.2.1) and Subject Registration Number Field (see 9.2.5) within

   the context of the subject's jurisdiction as specified in Section 9.2.4.

**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 9.2.5) within the context of the subject's

   jurisdiction as specified in Section 9.2.4.  The stated address of the organisation

   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 5:

1. Remove Registration Reference Provider.

2. Note that Registration References MAY contain hyphens, and clarify that the first hyphen is the separator.

3. Fix cross-references in Appendix H.

A comparison of the changes since version 5:


The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: May 6, 2019 4:00pm Eastern

End Time: May 13, 2019 4:15pm Eastern

Vote for approval (7 days)

Start Time: May 13, 2019 4:15pm Eastern

End Time: May 20, 2019 4:15pm Eastern

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