[cabf_validation] [EXTERNAL]Re: Proposed draft Ballot 225 to strengthen EVGL 11.6 - Operational Existence

[Tim Hollebeek]

I’ve supported this for a long time. As much as I hate country-by-country rules, I don’t think jurisdiction-neutral validation requirements can always be written for requirements like this.  The world’s legal systems are just too diverse.  I think even with very good rules, country-specific exceptions are inevitable.

We had similar issues with questions of simple geography, which don’t have uniform global understandings.

-Tim

I’d suggest this:  Let CAs who operate in other countries propose future amendments to EVGL 11.6 on a country-by-country basis, with reasons (e.g., “we can’t do those checks here because…”) and with a proposal for an alternative method for verifying an Applicant’s “operational existence” in that country, with facts and evidence.  The Forum can then review adopt those proposals on a country-by-country basis – limited to Applicants in those countries only – and add them in an Appendix to the EVGL.  This can grow over time as needed.

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