On Mon, Apr 23, 2018 at 1:11 PM, Henri Sivonen via dev-security-policy <
[email protected]> wrote:

> First, it seems to me that the Baseline Requirements allow
> transformations of the organization's name only if the CA documents
> such transformations. I am unable to find such documentation in
> DigiCert's CP and CPS documents. Am I missing something?
>

At present, these are not required to be in the public documentation.
Merely, the requirement is that the CA "documents" - i.e. it is presently
acceptable to only include this documentation in information provided to
the auditors.


> Second, while verifying that the applicant indeed represents a
> specific real organization is a difficult problem, in the case where
> the country that the certificate designates operates an
> online-queryable database of registered businesses, associations,
> etc., it should be entirely feasible to eliminate the failure mode
> where the certificate's organization field is (absent documented
> transformations permitted under the Baseline Requirements) not
> canonically equivalent (in the Unicode sense) to the name of any
> organization registered in the country that the certificates
> designates. That (inferring from the certificate for
> www.alandsbanken.fi) there isn't technical process that would by
> necessity remove diacritical marks from the organization field and
> that the certificate for www.saastopankki.fi has them removed is
> strongly suggestive that DigiCert's process for validating
> Finland-based organization does not include as a mandatory part either
> the retrieval of the organization's name via an online API to the
> business registry or a human CA representative copying and pasting the
> organization's name from a browser view to the business registry.
>

The Baseline Requirements do not dictate the datasource used in various
jurisdictions. Thus even when there is a canonical source through
legislation, the BRs do not require its use.


>  I wonder: When a given country

has an online-queryable business registry, why isn't it either
> recommended or required to import names digitally from the business
> registry into certificates? Such practice would eliminate the failure
> mode of the certificate designating a name that doesn't match any
> entry in the business registry for such country. (Obviously, if it was
> _required_, the BRs would need to include a list of countries whose
> business registry is considered online-queryable in the sense that the
> requirement would apply, but unwillingness to maintain such a list
> does not explain why it isn't even recommended.)
>

"Recommended" is pointless. Required is the only thing that makes sense,
and the complexities and overhead involved precisely explain why it isn't
required.
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