Owen,
Being completely pedantic about the RFC5280 text, nowhere in the text
does it say that rfc822name cannot be used for anything but email
address. It does state multiple times that an email address must be
represented as an rfc822name, but places no explicit restrictions on
what an rfc822name may represent. The text as is does not explicitly
preclude use of rfc822name for ACP. This may be the widespread
understanding of what RFC5280 means, but its not strictly what it says…
Common sense argues against putting something other than an e-mail
address in the rfc822namem attribute.
I expect ADs to use common sense, as well as careful reading of prior
RFCs, when making decisions.
Steve
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