>> I don’t think you should include #2 because it's a common practice to 
>> issue one certificate for Secure Mail that is used to both sign and 
>> encrypt, and this would preclude CA key generation for those types of 
>> certificates.
>>
>> I was attempting to match the existing "forbidden practice" 
>> requirement
>that carves out an exception only for email encryption.
>I don't know why that exception exists, but I do agree with you that it is 
>uncommon for an S/MIME certificate to support encryption but not signatures.

Actually it is very common: our CA has a couple of hundred thousand S/MIME 
certificates in the field, that are either for mail encryption or for mail 
signature but not for both. And I believe there are a lot of other enterprise 
CAs that do the same. There is a good reason for doing so: the private keys for 
both types of certificates are safely stored on our employees corporate ID 
smart card. But only the signature keys are also generated on the smart card. 
The encryption keys are generated centrally in the CA and then securely 
injected into the smart card. The reason for this split is, that we want to be 
absolutely sure, that the email signature is non-repudiationable by the holder 
of the card (as required by the European Unions eIDAS regulation for 'advanced 
electronic signature') but on the other hand side, we need to be able to 
perform a key escrow for the encryption keys, in case the card is damaged or 
lost or if there is court requirement to decrypt corporate emails and the 
holder of the card is not willing to do so.

Don't hesitate to contact me, if you want to know more, how it works in our 
case.

With best regards,
Rufus Buschart

Siemens AG
GS IT HR 7 4
Hugo-Junkers-Str. 9
90411 Nuernberg, Germany
Tel.: +49 1522 2894134
mailto:rufus.busch...@siemens.com

www.siemens.com/ingenuityforlife
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