[Smcwg-public] SMC05 - Subject:CountryName and organizationIdentifier matching requirement

[Christophe Bonjean]

Hi all

 

One of the changes in SMC05 clarifies that the LEI and INT registration
schemes should be excluded from the country matching requirement between the
Subject:CountryName and organizationIdentifier fields.

 

When further looking into this requirement, we noted that the country of a
legal entity does not always match with the country of registration. The EV
Guidelines actually have a provision for when the (physical) location is
different from the jurisdiction of incorporation in 11.4.1. 2 B "Place of
Business not in the Country of Incorporation or Registration".

 

For example, a legal entity can be registered by a national trade register
in one country, but the address of the legal entity can be in a nearby
country. 

 

When comparing to the EV guidelines, I was unable to find a similar country
match requirement in appendix H or 9.2.8 for the organizationIdentifier
field. The EV guidelines are also explicit about the location being a
physical location of the Subject's place of business, where this is less
explicit in 7.1.4.2.2 of the SMIME BRs.

 

Is there perhaps another reason or intention for the country matching
requirement, as we're not convinced this currently aligns with existing
legal entity registration practices?

 

Christophe

 

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