[Smcwg-public] [EXTERNAL]-Re: Common Name contents

Henschel, Andreas a.henschel at d-trust.net
Thu Mar 10 11:34:08 UTC 2022

Hey Dimitris,


in a first step, pseudonyms could be allowed in sponsored profiles. From an external point of view, those entities have the same accepted validation level as certificates with an organisation profile as the organisation is properly validated anyway.


Kind regards,



Von: Smcwg-public <smcwg-public-bounces at cabforum.org> Im Auftrag von Dimitris Zacharopoulos (HARICA) via Smcwg-public
Gesendet: Donnerstag, 10. März 2022 12:25
An: Juan Ángel Martín <martin_ja at camerfirma.com>; SMIME Certificate Working Group <smcwg-public at cabforum.org>
Betreff: Re: [Smcwg-public] [EXTERNAL]-Re: Common Name contents



On 10/3/2022 1:14 μ.μ., Juan Ángel Martín wrote:



One use case of pseudonyms that I know of is the need for the police to sign certain messages, e.g. traffic tickets, with a qualified eIDAS certificate.


But the police officers do not want their name, surname and personal identification document number to appear on the certificate, which signs the traffic ticket for unavoidable legal reasons in Europe.


I think it would be desirable to give an answer to this need in the CABF requirements for SMIME certificates.

Thank you Juan Ángel,

We all agree with the end goal but we can't address the concerns without answering some questions regarding the validation process. For example, what do those traffic tickets look like in terms of the signer? Does it only have a random identifier as described in the 2nd bullet of my previous letter? Does it say something like "Officer John"? It is important to get some transparency on this so the SMCWG can develop validation rules that would support this feature.

Best regards,



Juan Ángel


De: Smcwg-public  <mailto:smcwg-public-bounces at cabforum.org> <smcwg-public-bounces at cabforum.org> En nombre de Dimitris Zacharopoulos (HARICA) via Smcwg-public
Enviado el: jueves, 10 de marzo de 2022 10:40
Para: Wiedenhorst, Matthias  <mailto:M.Wiedenhorst at tuvit.de> <M.Wiedenhorst at tuvit.de>; SMIME Certificate Working Group  <mailto:smcwg-public at cabforum.org> <smcwg-public at cabforum.org>
Asunto: Re: [Smcwg-public] [EXTERNAL]-Re: Common Name contents



This is indeed a legal requirement in eIDAS and we need to see its applicability for S/MIME certificates.

The problem we need to address is the fact that I can validate myself to a CA with my physical presence and my official name (Dimitrios Zacharopoulos), and ask for a Pseudonym to be included in the certificate, but the process is unclear. Here are some questions/concerns (not addressed explicitly to Matthias, anyone can chime-in): 

1.	Could I ask that my pseudonym is "Matthias Wiedenhorst" or "Mickey Mouse"? How is THAT information validated so that it is not misleading to Relying Parties?
2.	Can the pseudonym be a name/value that the CA decides, e.g. "Pseudonym-482733812"? How is that helpful for Relying Parties?
3.	Can a Relying Party ask the CA to reveal the real identity of the person behind the pseudonym? If this is the case, how is this protecting the real person for being in danger?


On 10/3/2022 9:05 π.μ., Wiedenhorst, Matthias via Smcwg-public wrote:

Hi all!


Article 5 (2) eIDAS reads:

“Without prejudice to the legal effect given to pseudonyms under national law, the use of pseudonyms in electronic transactions shall not be prohibited.”


I am not a lawyer, but to me it sounds as if prohibiting pseudonyms could cause problems within the EU.


Legitimate use cases that I have heard of from different CAs are for example persons from the “law enforcement area” that are in danger to be threatened or even attacked in their private live when their full real name is known.

As already pointed out, a pseudonym certificate is not an anonymous certificate, but only the CA is able to reveal identity. Identification of the person has to be performed identically as if a certificate without pseudonym would be issued.


Best regards



Von: Smcwg-public  <mailto:smcwg-public-bounces at cabforum.org> <smcwg-public-bounces at cabforum.org> Im Auftrag von Stephen Davidson via Smcwg-public
Gesendet: Mittwoch, 9. März 2022 15:34
An: Pedro FUENTES  <mailto:pfuentes at WISEKEY.COM> <pfuentes at WISEKEY.COM>; SMIME Certificate Working Group  <mailto:smcwg-public at cabforum.org> <smcwg-public at cabforum.org>; Dimitris Zacharopoulos (HARICA)  <mailto:dzacharo at harica.gr> <dzacharo at harica.gr>
Betreff: Re: [Smcwg-public] [EXTERNAL]-Re: Common Name contents


In general, the CA is supposed to validate the true identity of a holder behind a subject:pseudonym.  This is different from an anonymous cert.

The difficulty we face is that, having chosen to require Subject identity information to be verified, it would be inconsistent to allow the freeform use of pseudonyms.

As far as I know, only Germany provides the options for alternative “religious names or pseudonyms” on their national ID: https://www.consilium.europa.eu/prado/en/DEU-BO-02004/image-344552.html ... So that significantly narrows the options for verifying pseudonyms!

My personal belief is that we should drop the use of pseudonyms from this draft.  I hope that SMCWG members that disagree with this will speak up.

The Mailbox-validated (MV) profiles are probably more appropriate for users not wishing “real name” identity to be in their certs.


Regards, Stephen



From: Smcwg-public <smcwg-public-bounces at cabforum.org <mailto:smcwg-public-bounces at cabforum.org> > On Behalf Of Pedro FUENTES via Smcwg-public
Sent: Monday, March 7, 2022 2:35 PM
To: Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr <mailto:dzacharo at harica.gr> >; SMIME Certificate Working Group <smcwg-public at cabforum.org <mailto:smcwg-public at cabforum.org> >
Subject: Re: [Smcwg-public] [EXTERNAL]-Re: Common Name contents


Could it be just acceptable that a pseudonym is freely chosen by a subscriber?

In other words… could it be acceptable to have names in the subjectName which don’t require validation?

We don’t currently use such attributes, but I wonder if this could be good to reserve certain flexibility for use cases where anonymization is desired. 



Le 7 mars 2022 à 18:58, Dimitris Zacharopoulos (HARICA) via Smcwg-public <smcwg-public at cabforum.org <mailto:smcwg-public at cabforum.org> > a écrit :

 Unless CAs have some clear rules on how to validate pseudonyms, I also believe we should exclude this attribute from the allowed profiles which makes this attribute practically not allowed. We must be explicit about this because other attributes may be allowed.


On 7/3/2022 9:41 π.μ., Adriano Santoni via Smcwg-public wrote:

We do not support pseudonyms, and do not think there is a need for them.

...we could even chose to exclude this attribute from the allowed profiles

Yes, that's what we suggest to do: exclude this attribute from the allowed profiles.



Il 02/03/2022 18:43, Stephen Davidson via Smcwg-public ha scritto:

Hi Doug:


1. Further to our discussion today, the language in ETSI EN 319 412-2 probably has the clearest definition:


The commonName attribute value shall contain a name of the subject. This may be in the subject's preferred presentation format, or a format preferred by the CA, or some other format. Pseudonyms, nicknames, and names with spelling other than defined by the registered name may be used. 


NOTE 1: The commonName attribute has a usage purpose that is different from the required choice of pseudonym or givenName/surname. commonName is used for user friendly representation of the person's name, whereas givenName/surname is used where more formal representation or verification of specific identity of the user is required. To maximize interoperability both are considered necessary.


It does not give guidance on the scope for “user friendly representation of the person's name” and as far as I can tell, most TSPs apply either (givenName and surname) or pseudonym in that field.


Notwithstanding this, our previous discussions had been for the commonName to include verified information for the purposes of the S/MIME BR, leading to the options described here <https://urldefense.proofpoint.com/v2/url?u=https-3A__github.com_cabforum_smime_blob_preSBR_SBR.md-2371422-2Dsubject-2Ddistinguished-2Dname-2Dfields&d=DwMDaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=-bX5hBm1IdRDykQ-dBR8tsFRCM4v1VXUyG7RZa2WqPY&m=NCuXVva5JxiZue0JFxEbVTEZS67ltuKPjLakEuBlN-Q&s=SikwTyV2nbwaM8CjAAm0ewzVcCUuXH_rrJl0zlNlYwQ&e=> .


We are interested in hearing perspectives from both Certificate Issuers and Certificate Issuers on this point.


2.  The handling of subject:pseudonym is still an unresolved issue – and so text still needs to be tightened up. We are working from the basis that Subject information must be verified, so this would also apply to pseudonym (ie not a self reported name). Pseudonym identity is, by definition, linked to the person’s real identity


ETSI TS 199 461 tries to deal with it by saying:


Although the outcome of the identity proofing can be a pseudonym identity, identity proofing requires identification of the real identity of the person as determined by applicable identity documents, official registers or other authoritative sources.


But as far as I can tell, only Germany provides pseudonym as an information attribute on official identity documents.  Given the lack of clarity, we could even chose to exclude this attribute from the allowed profiles.


We’d be interested to hear from Certificate Issuers what their practices are using the pseudonym in regulated certificate types.


Best, Stephen


Stephen Davidson 

DigiCert Governance, Risk & Compliance
stephen.davidson at digicert.com <mailto:stephen.davidson at digicert.com> 

O 1.441.278.2803 | M 1.441.505.4908




From: Doug Beattie  <mailto:doug.beattie at globalsign.com> <doug.beattie at globalsign.com> 
Sent: Wednesday, March 2, 2022 1:10 PM
To: Stephen Davidson  <mailto:Stephen.Davidson at digicert.com> <Stephen.Davidson at digicert.com>; SMIME Certificate Working Group  <mailto:smcwg-public at cabforum.org> <smcwg-public at cabforum.org>
Subject: Common Name contents


Hey Stephen,


During the call today it was mentioned that all of the subject info pulled from the certificates and displayed via GUI needs to be validated (no more OU logic). I went back and looked at the options for Sponsor validated certs and it permits the Pseudonym to be present in the CN.  


I went to check the rules for validation and found this:


f. Certificate Field: subject:pseudonym (
Contents: The pseudonym attribute MUST NOT be present if the givenName and/or surname attribute are present. If present, the subject:pseudonym field field MUST be verified according to Section 3.2.3 <https://urldefense.proofpoint.com/v2/url?u=https-3A__github.com_cabforum_smime_blob_preSBR_SBR.md-23323-2Dauthentication-2Dof-2Dindividual-2Didentity&d=DwMDaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=-bX5hBm1IdRDykQ-dBR8tsFRCM4v1VXUyG7RZa2WqPY&m=NCuXVva5JxiZue0JFxEbVTEZS67ltuKPjLakEuBlN-Q&s=nliz6I7gIbr8WMy3LZQ94CqxFqzTqVpunO8t0YqxuCo&e=> .


But I could not find any references to this field in that section, or section 3.2.4 that indicates how this is to be validated.  Are there CA validation rules for this, or can any value be supplied?






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