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title: Baseline Requirements for the Issuance and Management of Publicly-Trusted S/MIME Certificates
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subtitle: Version TBD
author:
- CA/Browser Forum
date: TBD
=======
subtitle: Version 1.0.7
author:
- CA/Browser Forum
date: November 22, 2024
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copyright: |
Copyright 2025 CA/Browser Forum
This work is licensed under the Creative Commons Attribution 4.0 International license.
Expand Down Expand Up @@ -92,11 +85,8 @@ The following Certificate Policy identifiers are reserved for use by CAs as a me
| 1.0.4 | SMC06 |Post implementation clarification and corrections | May 11, 2024 |
| 1.0.5 | SMC07 |Align Logging Requirement and Key Escrow clarification | July 15, 2024 |
| 1.0.6 | SMC08 |Deprecate Legacy Generation Profiles and Minor Updates | August 29, 2024 |
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| 1.0.X | TBD |ACME for S/MIME Automation | TBD |
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| 1.0.7 | SMC09 |Update to WebTrust requirements, require linting, minor edits | November 22, 2024 |
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| 1.0.X | TBD |ACME for S/MIME Automation | TBD |

\* Publication Date is the date the new version was published following the Intellectual Property Review.

Expand Down Expand Up @@ -294,8 +284,6 @@ The Definitions found in the [CA/Browser Forum's Network and Certificate System

**Legal Entity**: An association, corporation, partnership, proprietorship, trust, government entity or other entity with legal standing in a country's legal system.

**Linting**: A process in which the content of digitally signed data such as a Precertificate [RFC 6962], Certificate, CRL, or OCSP response, or data-to-be-signed object such as a `tbsCertificate` (as described in [RFC 5280, Section 4.1.1.1](https://tools.ietf.org/doc/html/rfc5280##section-4.1.1.1)) is checked for conformance with the profiles and requirements defined in these Requirements.

**Mailbox-Validated (MV)**: Refers to a Certificate Subject that is limited to (optional) `subject:emailAddress` and/or `subject:serialNumber` attributes.

**Mailbox Address**: Also Email Address. The format of a Mailbox Address is defined as a "Mailbox" as specified in Section 4.1.2 of [RFC 5321](https://tools.ietf.org/html/rfc5321) and amended by Section 3.2 of [RFC 6532](https://tools.ietf.org/html/rfc6532), with no additional padding or structure.
Expand Down Expand Up @@ -338,7 +326,7 @@ The Definitions found in the [CA/Browser Forum's Network and Certificate System

**Registration Authority (RA)**: Any Legal Entity that is responsible for identification and authentication of subjects of Certificates, but is not a CA, and hence does not sign or issue Certificates. An RA MAY assist in the certificate application process or revocation process or both. When "RA" is used as an adjective to describe a role or function, it does not necessarily imply a separate body, but can be part of the CA.

**Registration Reference**: An identifier assigned to a Legal 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 A.

Expand Down Expand Up @@ -620,11 +608,11 @@ To confirm the Applicant's control of the SMTP FQDN, the CA SHALL use only the c

The CA MAY confirm the Applicant's control over each Mailbox Field to be included in a Certificate using ACME for S/MIME as defined in RFC 8823. The CA's ACME server MAY respond to a POST request by sending the Random Value token components via email and SMTP, and then receiving a confirming response utilizing the generated Random Value, in accordance with RFC 8823.

Control over each Mailbox Address SHALL be confirmed using a unique Random Value. The Random Value token components SHALL only be shared in accordance with RFC 8823. Both token-part1 and token-part2 SHALL contain at least 128 bits of entropy.
Control over each Mailbox Address SHALL be confirmed using a newly-generated Random Value. The Random Value token components SHALL only be shared in accordance with RFC 8823. Both `token-part1` and `token-part2` as defined in RFC 8823 SHALL contain at least 128 bits of entropy.

The Random Value SHALL be unique in each Certificate Request. The Random Value SHALL remain valid for use in a confirming response for no more than 24 hours from its creation. The CA MAY specify a shorter validity period for Random Values in its CP and/or CPS.
The Random Value SHALL not be reused by the CA for other Certificate Requests. The Random Value SHALL remain valid for use in a confirming response for no more than 24 hours from its creation. The CA MAY specify a shorter validity period for Random Values in its CP and/or CPS.

There is no support for ACME External Account Binding in RFC 8823.
There is no support for ACME External Account Binding in RFC

### 3.2.3 Authentication of organization identity

Expand All @@ -639,15 +627,15 @@ The CA or RA SHALL collect and retain evidence supporting the following identity
3. An Affiliate of the Legal Entity as described in Section 7.1.4.2.2 (if included in the Subject as an `subject:organizationalUnitName`);
4. An address of the Legal Entity (if included in the Subject);
5. Jurisdiction of Incorporation or Registration of the Legal Entity; and
6. Identifier and type of identifier for the Legal Entity.
6. Unique identifier and type of identifier for the Legal Entity.

The identifier SHALL be included in the Certificate `subject:organizationIdentifier` as specified in [Section 7.1.4.2.2](#71422-subject-distinguished-name-fields) and [Appendix A](#appendix-a---registration-schemes).
The unique identifier SHALL be included in the Certificate `subject:organizationIdentifier` as specified in [Section 7.1.4.2.2](#71422-subject-distinguished-name-fields) and [Appendix A](#appendix-a---registration-schemes).

#### 3.2.3.2 Validation of organization identity

If an Attestation is used as evidence for the validation of the attributes described in this section, then the Attestation SHALL be verified for authenticity as described in [Section 3.2.8](#328-reliability-of-verification-sources).

##### 3.2.3.2.1 Verification of name, address, and identifier
##### 3.2.3.2.1 Verification of name, address, and unique identifier

The CA or RA SHALL verify the full legal name and an address (if included in the Certificate Subject) of the Legal Entity Applicant using documentation provided by, or through communication with, at least one of the following:

Expand All @@ -673,7 +661,7 @@ The CA MAY rely on an Attestation that indicates the Assumed Name under which th

#### 3.2.3.3 Disclosure of verification sources

The CA or RA SHALL verify the Registration Reference to be included in the Certificate from a register that is maintained or authorized by the relevant government agency. The CA SHALL disclose the authorized sources it uses to verify the Applicant's creation, existence, or recognition. This disclosure SHALL be through an appropriate and readily accessible online means. The CA SHALL document where to obtain this information within Section 3.2 of the CA's CP and/or CPS.
The CA or RA SHALL verify the unique identifier used in the Certificate from a register that is maintained or authorized by the relevant government agency. The CA SHALL disclose the authorized sources it uses to verify the Applicant's creation, existence, or recognition. This disclosure SHALL be through an appropriate and readily accessible online means. The CA SHALL document where to obtain this information within Section 3.2 of the CA's CP and/or CPS.

Nothing in these Requirements prohibits the use of third-party vendors to obtain regularly-updated and current information from the government register provided that the third party obtains the information directly from the government.

Expand Down Expand Up @@ -952,35 +940,8 @@ No stipulation.

### 4.3.1 CA actions during certificate issuance

#### 4.3.1.1 Manual authorization of certificate issuance for Root CAs

Certificate issuance by the Root CA SHALL require at least two individuals authorized by the CA (i.e., the CA system operator, system officer, or PKI administrator) one of whom deliberately issues a direct command in order for the Root CA to perform a Certificate signing operation.

#### 4.3.1.2 Linting of to-be-signed Certificate content

It is considered best practice for the CA to implement a Linting process to test the technical conformity of each to-be-signed artifact prior to signing it.

Effective March 15, 2025 the CA SHOULD implement a Linting process testing compliance with these Requirements for S/MIME Certificates. Effective September 15, 2025 the CA SHALL implement a Linting process testing compliance with these Requirements for S/MIME Certificates.

Methods used to produce a Certificate containing the to-be-signed Certificate content include, but are not limited to:

1. Sign the `tbsCertificate` with a "dummy" Private Key whose Public Key component is not certified by a Certificate that chains to a publicly-trusted CA Certificate; or
2. Specify a static value for the `signature` field of the Certificate ASN.1 SEQUENCE.

CAs MAY implement their own Certificate Linting tools, but CAs SHOULD use the Linting tools that have been widely adopted by the industry (see https://cabforum.org/resources/tools/).

CAs are encouraged to contribute to open-source Linting projects, such as by:

* Creating new or improving existing lints;
* Reporting potentially inaccurate linting results as bugs;
* Notifying maintainers of Linting software of checks that are not covered by existing lints;
* Updating documentation of existing lints; and
* Generating test Certificates for positive/negative tests of specific lints.

#### 4.3.1.3 Linting of issued Certificates

CAs MAY use a Linting process to test each issued Certificate.

### 4.3.2 Notification to subscriber by the CA of issuance of certificate

No stipulation.
Expand Down Expand Up @@ -2205,7 +2166,7 @@ c. __Certificate Field:__ `subject:organizationalUnitName` (OID: 2.5.4.11)
__Contents:__ If present, the CA SHALL confirm that the `subject:organizationalUnitName` is the full legal organization name of an Affiliate of the `subject:organizationName` in the Certificate and has been verified in accordance with the requirements of [Section 3.2.3](#323-authentication-of-organization-identity). The CA MAY include information in this field that differs slightly from the verified name, such as common variations or abbreviations, provided that the CA documents the difference and any abbreviations used are locally accepted abbreviations.

d. __Certificate Field:__ `subject:organizationIdentifier` (2.5.4.97)
__Contents:__ If present, the `subject:organizationIdentifier` field SHALL contain a Registration Reference for a Legal Entity assigned in accordance to the identified Registration Scheme. The Registration Reference SHOULD be unique where the Registration Scheme and jurisdiction provide unique identifiers.
__Contents:__ If present, the `subject:organizationIdentifier` field SHALL contain a Registration Reference for a Legal Entity assigned in accordance to the identified Registration Scheme.

The `subject:organizationIdentifier` SHALL be encoded as a PrintableString or UTF8String.

Expand All @@ -2219,10 +2180,10 @@ d. __Certificate Field:__ `subject:organizationIdentifier` (2.5.4.97)

**Note 1**: Registration References MAY contain hyphens but Registration Schemes, ISO 3166-1 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. For example:

* `NTRGB-12345678` (NTR scheme, Great Britain, Registration Reference at Country level is 12345678).
* `NTRUS+CA-12345678` (NTR Scheme, United States - California, Registration Reference at State level is 12345678).
* `VATDE-123456789` (VAT Scheme, Germany, Registration Reference at Country Level is 12345678).
* `PSDBE-NBB-1234.567.890` (PSD Scheme, Belgium, NCA's identifier is NBB, Registration Reference assigned by the NCA is 1234.567.890).
* `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, Unique Identifier assigned by the NCA is 1234.567.890).

Registration Schemes listed in [Appendix A](#appendix-a---registration-schemes) are recognized as valid under these Requirements. The CA SHALL:

Expand All @@ -2239,8 +2200,6 @@ d. __Certificate Field:__ `subject:organizationIdentifier` (2.5.4.97)
* GOVUS+CA (Government Entity, United States - California)
* INTXG (International Organization)

**Note 3**: For the NTR Registration Scheme, where the Legal Entity is registered within a European country, the NTR Registration Scheme SHALL be assigned at the country level.

e. __Certificate Field:__ `subject:givenName` (2.5.4.42) and/or `subject:surname` (2.5.4.4)
__Contents:__ If present, the `subject:givenName` field and `subject:surname` field SHALL contain a Natural Person Subject’s name as verified under [Section 3.2.4](#324-authentication-of-individual-identity). Subjects with a single legal name SHALL provide the name in the `subject:surname` attribute. The `subject:givenName` and/or `subject:surname` SHALL NOT be present if the `subject:pseudonym` is present.

Expand Down Expand Up @@ -2446,7 +2405,7 @@ The Subordinate CA and the Issuing CA SHALL represent, in their CP and/or CPS, t

A Certificate issued to a Subscriber SHALL contain, within the Certificate's `certificatePolicies` extension, a policy identifier that is specified in [Section 7.1.6.1](#7161-reserved-certificate-policy-identifiers).

The Certificate MAY also contain additional policy identifier(s) documented by the Issuing CA in its CP and/or CPS.
The Certificate MAY also contain additional policy identifier(s) defined by the Issuing CA. The Issuing CA SHALL document in its CP and/or CPS that the Certificates it issues containing the specified policy identifier(s) are managed in accordance with these Requirements.

### 7.1.7 Usage of policy constraints extension

Expand Down Expand Up @@ -2537,9 +2496,8 @@ The CA SHALL undergo an audit in accordance with one of the following schemes:

1. For Audit Periods starting before the Effective Date defined in [Section 1.2.1](#121-revisions) of the first version of these Requirements, “WebTrust for CAs v2.2.2 or newer”; or
2. For Audit Periods starting after the Effective Date defined in [Section 1.2.1](#121-revisions) of the first version of these Requirements, “WebTrust for CAs v2.2.2 or newer” AND “WebTrust for S/MIME Baseline Requirements v1.0.0 or newer”; or
3. For Audit Periods starting after April 1, 2025, “WebTrust for CAs v2.2.2 or newer” AND “WebTrust for S/MIME Baseline Requirements v1.0.0 or newer” AND “WebTrust for Network Security v2.0 or newer”; or
4. ETSI TS 119 411-6 v1.1.1 or newer, which includes normative references to ETSI EN 319 401, ETSI EN 319 411-1 and ETSI EN 319 411-2 (the latest version of the referenced ETSI documents should be applied); or
5. If a Government CA is required by its Certificate Policy to use a different internal audit scheme, it MAY use such scheme provided that the audit either
3. ETSI TS 119 411-6 v1.1.1 or newer, which includes normative references to ETSI EN 319 401, ETSI EN 319 411-1 and ETSI EN 319 411-2 (the latest version of the referenced ETSI documents should be applied); or
4. If a Government CA is required by its Certificate Policy to use a different internal audit scheme, it MAY use such scheme provided that the audit either
a. encompasses all requirements of one of the above schemes; or
b. consists of comparable criteria that are available for public review.
Whichever scheme is chosen, it SHALL incorporate periodic monitoring and/or accountability procedures to ensure that its audits continue to be conducted in accordance with the requirements of the scheme.
Expand Down Expand Up @@ -2582,8 +2540,6 @@ The Audit Report SHALL be available as a PDF, and SHALL be text searchable for a

During the period in which the CA issues Certificates, the CA SHALL monitor adherence to its CP and/or CPS and these Requirements and control its service quality by performing self audits on at least a quarterly basis against a randomly selected sample including a minimum of the greater of thirty (30) Certificates or three percent (3%) of the Certificates issued by it during the period commencing immediately after the previous self-audit sample was taken.

Effective March 15, 2025 the CA SHOULD use a Linting process to verify the technical accuracy of Certificates within the selected sample set independently of previous linting performed on the same Certificates.

## 8.8 Review of delegated parties

Except for Delegated Third Parties, Enterprise RAs, and Technically Constrained Subordinate CAs that undergo an annual audit that meets the criteria specified in [Section 8.4](#84-topics-covered-by-assessment), the CA SHALL ensure the practices and procedures of delegated parties are in compliance with these Requirements and the relevant CP and/or CPS. The CA shall document the obligations of delegated parties and perform monitoring on at least an annual basis of the delegated parties' adherence with those obligations.
Expand Down Expand Up @@ -2863,11 +2819,7 @@ The following Registration Schemes are recognized as valid for use in the `subje

* **PNO**: For an identifier based on a national personal number (or national civic registration number) issued to the Subject Individual.

* **TAX**: For an identifier based on a personal tax reference number issued by a national tax authority.

* **TIN**: For an identifier based on Tax Identification Number issued to the Subject Individual according to the [European Commission - Tax and Customs Union](https://ec.europa.eu/taxation_customs/tin/tinByCountry.html).

* **EID**: For an identifier based on electronic identification means (e.g., national eID or EU wallet)
* **TIN**: For an identifier based on Tax Identification Number issued to the Subject Individual.

# Appendix B - Transition of Extant S/MIME CAs

Expand Down

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