Hi

Late last week we discovered three certificates issued from Buypass with an 
error in the subject:PostalCode for one dutch company. One of these 
certificates is available at https://crt.sh/?id=212774960

The postalcode should have been '3707BK' as registered in the European Business 
Register (EBR), but these three certificates were issued with the value 
'NLD-3707BK' where NLD is the 3 letter UN country code for the Netherlands.

The inclusion of the three letter country code was indirectly caused by 
retrieving a three letter UN country code, instead of the two letter ISO 3166 
country code. The three letter country code was then changed into a two letter 
country code to comply with BR 7.1.4.2.2 h). However, this change caused a 
formatting error in another data field used as input to the postalCode 
attribute and then again the inclusion of the three letter country code in the 
postalCode field in the certificates.

We have checked all issued certificates and concluded that these are the only 
three certificates with this error.

We consider this error to be minor since the certificates includes the zip or 
postal information as specified by BR 7.1.4.2.2 g),  only prefixed with the 
country code. We have decided to not revoke the affected certificates since we 
do not consider this to represent any security concern and since the 
information is not misleading. This decision has also been discussed with our 
auditor.

However, since this is a deviation from our standard procedures (and not 
necessarily in compliance with the requirements), we decided to handle this as 
a "misissuance" and therefore send this incident report.

We will add an additional check in our certificate issuance system to identify 
any errors in the formatting of the postalCode field - together with a 
cablint/certlint control which already is planned.  This will prevent issuance 
of certificates with this formatting error. These extra controls will be 
released by the end of this week.

We have also identified a bug fix for the country code formatting error, but 
this fix has not yet been scheduled.

Regards
Mads

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