Stephen My primary concern with the proposed change is that once it finds it's way into the BR, anyone not in the EU will be eliminated from trusting existing digital signatures as evidence. For example, here in the U.S., the U.S. Government has an extremely robust digital credential based on a full background check that is independently assessed and accompanied by reams of documentation, regulation and policy. Over 7 million individuals hold these credentials. But by this policy, signatures from this community would not be sufficient as evidence. The CertiPath community, comprised of major Aerospace Corporations, would likewise be eliminated. While we don't employ the same level of background checks in our identity proofing, it is certainly based on sound practice and audited annually under WebTrust for CA, which may not be a "national scheme" but is certainly a robust review process widely recognized in the U.S. and Canada.
Unless you are prepared to identify schemes that cover all other regions of the world, I believe it is too early to make this change. As a compromise, I suggest you could identify eIDAS as the qualifying scheme for Europe and remain silent on the rest of the world. I recommend you revise the opening as follows: "If a digital signature is to be used as evidence in the European Union, the CA or RA SHALL only rely upon the following certificate type:" Once sufficient assessment has taken place to include all participating regions, the language could be further modified as you suggest. Judy Judith Spencer | PMA Chair | CertiPath, Inc. 1900 Reston Metro Plaza, Suite 303, Reston, VA 20190 PH +1.301.974.4227 Email <mailto:judith.spen...@certipath.com> judith.spen...@certipath.com From: Smcwg-public <smcwg-public-boun...@cabforum.org> On Behalf Of Stephen Davidson via Smcwg-public Sent: Wednesday, April 24, 2024 8:06 PM To: smcwg-public@cabforum.org Subject: [External] [Smcwg-public] Draft proposal to add eIDAS QES as vetting evidence for individual Hello all: As discussed today, here is draft language for consideration to allow CAs to rely upon signatures created with eIDAS Qualified certificates as evidence supporting validation of individual identity. https://github.com/srdavidson/QES-SMIME-BR/blob/master/QES-proposal.md I'd be grateful for feedback on this language. Best, Stephen
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