We have had a number of discussions over the last few months about the content 
of Subject Names in Certificates.  I promised on a recent call to try to 
summarize one of the issues, including the issue that Li-Chun has raised.

The Baseline Requirements specify how Names are to be constructed.  There are 
rules about which attributes must appear in names and what the content of the 
attributes must be.

There are other existing PKIs with different naming rules.  Another PKI could 
forbid an attribute required by the BRs.  Alternatively another PKI could 
require that the full Name be taken verbatim from some other source, such as an 
existing Directory Information Tree; these Names many not include attributes 
required by the BRs.

I believe the government on Taiwan falls into the latter case.  They have a PKI 
which has the policy that names must be taken from an existing Directory 
Information Tree operated by the government.  Many of the Names in the existing 
DIT don’t include attributes that are required by the BRs.  Therefore the 
question is whether we should make an exception to allow this existing PKI to 
be declared BR-compliant by adding some language like “ If a Government CA is 
required by its Certificate Policy to use Subject Names from a Directory 
Information Tree operated by a Government Entity, then section 7.1.4.2.2 shall 
not apply.”

Li-Chun: Did I get this right?

Others: Does this make the issue clearer?

Thanks,
Peter
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