Thank you both. From my standpoint, in this particular example and Clint's additional context, it could go both ways. At the end of the day, as long as the language is clear and unambiguous, it can be placed in any part of the document :)

In order to maintain strict RFC 2119 conformance, the definition of the Random Value must include the words MUST/SHALL for the 112 bits of entropy and similarly in other parts of the document. I don't think anyone can challenge the existing requirement as written, but this is a technicality that could be fixed throughout the document in a clean-up ballot. The expectations/results would be exactly the same, but the output style will be more compatible with RFC 2119.

Dimitris.

On 28/8/2024 11:57 μ.μ., Tim Hollebeek wrote:

That’s a fair point, and thank you for the additional discussion. There is in fact a large grey area between black and white, as there usually is.

The reason this one crossed the line into a normative requirement for me was largely because it defined a Date of Formation, and then was talking about how that date should be formatted (which requires usage and context), which I personally think is clearly outside the boundaries of what a Date of Formation **is**.

The  gray area is exactly where you describe, where there can be disagreements about what is an essential property of a thing, and what are requirements around a thing. For example, if you had written:

Date of Formation: A ten character string that specifies the date where a Legal Entity was first recognized by the jurisdiction in which it was created or formed, in the form of a complete representation of an extended format calendar date (“YYYY-MM-DD”) in ISO 8601.

Then that clearly defines a thing. I don’t like defining it that way, but it works. We’re now defining a string, and characterizing its contents independently of any requirements of how it gets used. The definition is self-contained and the world is good again. Sort of.

Forward and up,

-Tim

*From:*Clint Wilson <cli...@apple.com>
*Sent:* Wednesday, August 28, 2024 4:25 PM
*To:* Tim Hollebeek <tim.holleb...@digicert.com>
*Cc:* CABforum3 <validation@cabforum.org>; Dimitris Zacharopoulos (HARICA) <dzach...@harica.gr> *Subject:* Re: [cabf_validation] Proposed ballot on improving Registration Number language in EVGs

This is helpful.

To be clear, I agree that normative requirements should be avoided in definitions, however based on your response to this proposed definition change, it’s also clear there’s some difference of opinion on what counts as (or doesn’t) a normative requirement. For example, what sections of the (T/S/CS)BRs constitute the body of the document? Is it just Section 1.6 that should be void of normative requirements? Should normative requirements be pulled out of Section 1 entirely? Since we don’t introduce RFC 2119 language until Section 1.6.4, does that mean all uses of those terms in prior sections are incorrect in some way? How would such a shift impact maintainability of the document, for example in a scenario where a defined term has its requirements pulled into a separate section, but then a later usage of that term doesn’t remember to include these “extra” properties of the term as used in a specific section?

When I think of a definition, I assume two basic components: the term being defined and the exact meaning of a word, including the properties, attributes, or characteristics that term and meaning encompass. For example, I don’t see the definition of Random Value as containing normative requirements; rather, it’s describing that in order for a random value to /be/ a random value, it needs to exhibit 112 bits of entropy. Is there a “MUST” implied in the requirement that the Reliable Method of Communication be verified by the CA? Should Wildcard Domain Name not specify the unicode character codes of the defined characters?

When I think about pulling normative requirements out of definitions, I’m thinking more of terms like Request Token (because it does clearly espouse sets of interacting requirements and options) and Authorization Domain Name (because the concept is complex enough to warrant expansion in the context of its use rather than solely within the definition).

My suggestion of including the format in the definition for Date of Formation was intended to convey that this formatting is an intrinsic property of the thing being defined. Moving that down into the profile section is completely acceptable to me. The related suggestion that this property of the defined term is a requirement that /can't/ be included in a definition has me confused about the actual expected outcome to the content, organization, and accessibility of the BRs if that statement is applied at face value.

Cheers,

-Clint



    On Aug 27, 2024, at 9:58 AM, Tim Hollebeek
    <tim.holleb...@digicert.com> wrote:

    My opinion is that all requirements need to be stated in RFC 2119
    language and be present in the body of the document in order to be
    treated as normative requirements. That should be an
    uncontroversial view. I suspect our auditor friends have a similar
    view. I don’t think it’s a particularly hard line or strict view,
    it’s just what’s necessary to prevent ambiguity as to what the
    requirements are.

    I would be fine with once in the section. Something along the
    lines of “The Date of Formation MUST be formatted according to the
    complete representation of an extended format calendar date in ISO
    8601 (i.e. YYYY-MM-DD; e.g. 0001-01-01).”

    -Tim

    *From:*Clint Wilson <cli...@apple.com>
    *Sent:*Tuesday, August 27, 2024 9:06 AM
    *To:*Tim Hollebeek <tim.holleb...@digicert.com>; CABforum3
    <validation@cabforum.org>
    *Cc:*Dimitris Zacharopoulos (HARICA) <dzach...@harica.gr>
    *Subject:*Re: [cabf_validation] Proposed ballot on improving
    Registration Number language in EVGs

    Hi Tim,

    I think including the format of this specific date type in the
    definition is totally reasonable, given that it’s not applicable
    to any other date types and so can very much exist intrinsically
    as part of the definition. That is, I don’t agree with the
    seemingly hard line you’re drawing in your statement — and, even
    moreso, I don’t believe such a statement is backed by consensus
    within the Forum so I also don’t want it construed as more than
    your opinion, as indeed is my above statement that it can be part
    of the definition.

    All that said, I do agree putting it in-line in the EVGs would
    work just fine too. Are you then imagining we would repeat this
    format requirement alongside each of the four times the term is
    used in 7.1.4.2.5 or just state it once somewhere in that section?
    Do you have some example text you can provide to show what you’re
    proposing as an alternative approach?

    Thank you,

    -Clint




        On Aug 26, 2024, at 10:32 AM, Tim Hollebeek via Validation
        <validation@cabforum.org> wrote:

        This is a requirement, and any requirements around how dates
        should be formatted need to be stated as such in the
        appropriate profile section. It MUST NOT be stated in the
        definition.

        -Tim

        *From:*Validation <validation-boun...@cabforum.org>*On Behalf
        Of*Dimitris Zacharopoulos (HARICA) via Validation
        *Sent:*Friday, August 23, 2024 2:26 AM
        *To:*CABforum3 <validation@cabforum.org>
        *Subject:*Re: [cabf_validation] Proposed ballot on improving
        Registration Number language in EVGs

        On 16/8/2024 2:53 π.μ., Clint Wilson via Validation wrote:

            Hi Corey,

            Overall this seems like a good improvement to clarity of
            the current expectations related to these sections of the
            EVGs, reflecting the predominant approach to populating
            the subject:serialNumber field for EV TLS certificates. I
            do think it would be valuable to standardize on a date
            format (admittedly somewhat because it feels like a missed
            opportunity to not do so). What about something like
            modifying the newly added definition:

                **Date of Formation**: The date on which a Legal
                Entity is first recognized by the jurisdiction in
                which it was created or formed. The date is formatted
                according to the complete representation of an
                extended format calendar date in ISO 8601 (i.e.
                YYYY-MM-DD; e.g. 0001-01-01).


        Hi Clint,

        I'm in favor of examples where they help avoid unintended
        mistakes, so I would support adding something like "e.g.
        2000-12-31" to make it abundantly clear where the month and
        day is supposed to be represented.


        Thanks,
        Dimitris.




            The parenthetical is probably too much, but you get the
            idea. And then the three instances of "in any one of the
            common date formats” could just be deleted.

            Cheers,

            -Clint





                On Aug 9, 2024, at 8:55 AM, Corey Bonnell via
                Validation<validation@cabforum.org>
                <mailto:validation@cabforum.org>wrote:

                Hello,

                Some time ago, I presented [1] a ballot proposal on
                improving the requirements for the Registration Number
                value in the EVGs. Here is the current
                
proposal:https://github.com/cabforum/servercert/compare/main...CBonnell:servercert:govt-entity-serial-number
                
<https://github.com/cabforum/servercert/compare/main...CBonnell:servercert:govt-entity-serial-number>.

                On the call where the proposal was presented, there
                was a desire to explore standardizing date formats for
                the Date of Formation. Is this something that we would
                like to see added to the ballot? For the sake of
                minimizing scope of the ballot, I’m in favor of moving
                forward without such a requirement, but will certainly
                be happy to incorporate if there are strong feelings
                that such a requirement should be added in this ballot.

                Thanks,

                Corey

                
[1]https://lists.cabforum.org/pipermail/validation/2024-July/001997.html
                
<https://lists.cabforum.org/pipermail/validation/2024-July/001997.html>

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