To be honest, this section has been causing me concerns for some time. However, I was waiting for some additional clarification on how it would be implemented. How exactly qualifying schemes were going to be identified and included. This feels arbitrary. In addition, from experience, approving a single scheme, such as eIDAS will cause confusion for all the non-EU organizations. Hence my suggestion for a modification to the language.
Judy Judith Spencer | PMA Chair | CertiPath, Inc. 1900 Reston Metro Plaza, Suite 303, Reston, VA 20190 PH +1.301.974.4227 Email <mailto:judith.spen...@certipath.com> judith.spen...@certipath.com From: Clint Wilson <cli...@apple.com> Sent: Thursday, April 25, 2024 10:48 AM To: Judith Spencer <judith.spen...@certipath.com>; SMIME Certificate Working Group <smcwg-public@cabforum.org> Cc: Stephen Davidson <stephen.david...@digicert.com> Subject: [External] Re: [Smcwg-public] [External] Draft proposal to add eIDAS QES as vetting evidence for individual Hi Judith, As I understand it, the proposed change is purely additive. That is, currently there are no approved frameworks in the SBRs meaning that there is no way for a compliant CA to rely upon a digital signature as evidence for the collection of Individual identity attributes (or any other purpose, I believe, but haven’t checked outside of Section 3.2.4.1 as closely). From my reading, this change doesn’t eliminate the ability for those not in the EU to trust existing digital signatures as evidence as no such ability exists today. Rather, this change would only add the ability to rely on digital signatures created by a subset of eIDAS Electronic Qualified Signature Certificates. While that is still limited in scope, as you indicate, it also doesn’t remove anything already allowed by the SBRs. Can you help me understand better where you see the current SBRs as allowing CAs to rely upon digital signatures in the context of 3.2.4.1 today? Thank you! -Clint On Apr 25, 2024, at 7:20 AM, Judith Spencer via Smcwg-public <smcwg-public@cabforum.org <mailto:smcwg-public@cabforum.org> > wrote: Stephen My primary concern with the proposed change is that once it finds it’s way into the BR, anyone not in the EU will be eliminated from trusting existing digital signatures as evidence. For example, here in the U.S., the U.S. Government has an extremely robust digital credential based on a full background check that is independently assessed and accompanied by reams of documentation, regulation and policy. Over 7 million individuals hold these credentials. But by this policy, signatures from this community would not be sufficient as evidence. The CertiPath community, comprised of major Aerospace Corporations, would likewise be eliminated. While we don’t employ the same level of background checks in our identity proofing, it is certainly based on sound practice and audited annually under WebTrust for CA, which may not be a “national scheme” but is certainly a robust review process widely recognized in the U.S. and Canada. Unless you are prepared to identify schemes that cover all other regions of the world, I believe it is too early to make this change. As a compromise, I suggest you could identify eIDAS as the qualifying scheme for Europe and remain silent on the rest of the world. I recommend you revise the opening as follows: “If a digital signature is to be used as evidence in the European Union, the CA or RA SHALL only rely upon the following certificate type:” Once sufficient assessment has taken place to include all participating regions, the language could be further modified as you suggest. Judy Judith Spencer | PMA Chair | CertiPath, Inc. 1900 Reston Metro Plaza, Suite 303, Reston, VA 20190 PH +1.301.974.4227 Email <mailto:judith.spen...@certipath.com> judith.spen...@certipath.com From: Smcwg-public <smcwg-public-boun...@cabforum.org <mailto:smcwg-public-boun...@cabforum.org> > On Behalf Of Stephen Davidson via Smcwg-public Sent: Wednesday, April 24, 2024 8:06 PM To: smcwg-public@cabforum.org <mailto:smcwg-public@cabforum.org> Subject: [External] [Smcwg-public] Draft proposal to add eIDAS QES as vetting evidence for individual Hello all: As discussed today, here is draft language for consideration to allow CAs to rely upon signatures created with eIDAS Qualified certificates as evidence supporting validation of individual identity. <https://github.com/srdavidson/QES-SMIME-BR/blob/master/QES-proposal.md> https://github.com/srdavidson/QES-SMIME-BR/blob/master/QES-proposal.md I’d be grateful for feedback on this language. Best, Stephen _______________________________________________ Smcwg-public mailing list Smcwg-public@cabforum.org <mailto:Smcwg-public@cabforum.org> https://lists.cabforum.org/mailman/listinfo/smcwg-public
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