Hi,

I recently noticed that a lot of leaf certificates [0] have
organizationalUnitName specified without other organizational
information such as organizationName. Many times this field is used
for branding purposes, e.g. "issued through <someone's kpi manager>"
or "SomeBrand SSL".

BR v1.6.6 ยง 7.1.4.2.2i has guidance on usage of the OU field: "The CA
SHALL implement a process that prevents an OU attribute from including
a name, DBA, tradename, trademark, address, location, or other text
that refers to a specific natural person or Legal Entity unless the CA
has verified this information in accordance with Section 3.2 and the
Certificate also contains subject:organizationName, ,
subject:givenName, subject:surname, subject:localityName, and
subject:countryName attributes, also verified in accordance with
Section 3.2.2.1."

As the organizationName and other related attributes are not set in
many of those certificates, even though e.g. "COMODO SSL Unified
Communications" is a very strong reference to Sectigo's ssl branding &
business, I believe the referenced certificate is not issued in line
with the BR.

Is the above interpretation of BR section 7.1.4.2.2i correct?

- Matthias

[0] please find attached 3 files which contain a query on the crt.sh
database, with their results ( queried 2019-10-30T10:00:00Z and
T12:00:00Z )
The queries count certificate IDs in the range 1890000000 ...
1900000000 (10M possible certificate IDs), and are filtering
certificates which have an organizationalUnitName <> 'Domain Control
Validated', but not the organizationName field:
- cert_no_dcv: Total count count of the filtered certificate_ids
- cert_by_issuer_no_dcv: Counted, grouped by issuer ID. This can
contain duplicate counts, but only due to multiple issuer_ca_ids per
certificate, which should not exist.
- cert_by_issuer_name_no_dcv: Counted, grouped by issuer &
organizationalUnitName: Certificates may be counted twice here due to
multiple OU entries for one certificate.
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