A mistake in the BRs (I wrote the language unfortunately so shame on me for not 
matching the other sections of org name or the given name). There's no 
certificate that ever contains all of these fields. How would you ever have 
that?

There's no requirement that the OU field information relate to the O field 
information as long as the information is verified. 

-----Original Message-----
From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> On 
Behalf Of Alex Cohn via dev-security-policy
Sent: Friday, November 1, 2019 9:13 AM
To: Kurt Roeckx <k...@roeckx.be>
Cc: Matthias van de Meent <matthias.vandeme...@cofano.nl>; MDSP 
<dev-security-policy@lists.mozilla.org>
Subject: Re: Certificate OU= fields with missing O= field

On Fri, Nov 1, 2019 at 5:14 AM Kurt Roeckx via dev-security-policy 
<dev-security-policy@lists.mozilla.org> wrote:
>
> On Fri, Nov 01, 2019 at 11:08:23AM +0100, Matthias van de Meent via 
> dev-security-policy wrote:
> > 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 § 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?
>
> That OU clearly doesn't have anything to do with the subject that was 
> validated, so I also consider that a misissue.
>
>
> Kurt

A roughly-equivalent Censys.io query, excluding a couple other unambiguous 
"domain validated" OU values: "not _exists_:
parsed.subject.organization and _exists_:
parsed.subject.organizational_unit and not
parsed.subject.organizational_unit: "Domain Control Validated" and not
parsed.subject.organizational_unit: "Domain Validated Only" and not
parsed.subject.organizational_unit: "Domain Validated" and
validation.nss.valid: true" returns 17k hits.

IMO the "Hosted by ____.Com" certs fail 7.1.4.2.2i - the URL of a web host is 
definitely "text that refers to a specific ... Legal Entity".

> 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.

I'm pretty sure this isn't what the BRs intended, but this appears to forbid 
issuance with a meaningful subject:organizationalUnitName unless all of the 
above attributes are populated. EVG §9.2.9 forbids including those attributes 
in the first place. Am I reading this wrong, or was this an oversight in the 
BRs?
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