> However I still hold out some hope that the current proposal could be 
> workable.  I'm sorry if I missed it in the thread or bug, what is the 
> rationale that a "AC FNMT Usuarios" doesn't require an ongoing WebTrust SSL 
> BRs audit?
> 
Hi Andrew.

As specified at CABForum Baseline Requirements documents, these requirements 
only address certificates intended to be used for autenticating servers 
accessible through Internet.

Notice that "AC FNMT Usuarios" issues qualified certificates for natural 
persons (citizens). Therefore, it can't be audited conforming BR requirements 
because we don't issue SSL certs with this subCA (in fact, we have technical 
configuration restrictions to prevent SSL certs issuing).

As I mentioned, "AC FNMT Usuarios" only issues "qualified certificates" where 
ETSI 101 456 audit criteria applies. Nevertheless, because this subordinate CA 
don't have the EKU extension, according to "CA:BaselineRequirements" document 
at mozilla wiki, "AC FNMT Usuarios" is "in scope" and it's necessary to perform 
"procedures to confirm that there are no SSL certificates".

Best Regards,

Rafa
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