(Mozilla hat off.)

After reading about the California versus Delaware thing when it comes
to the certificate for stripe.com, out of curiosity, I took a fresh
look at the ISO 3166-1 code in the EV certificates of some of the
banks that operate in Finland. (Result: https://www.nordea.fi/ is SE,
https://www.handelsbanken.fi/ is SE but https://danskebank.fi/ is FI
and not DK.)

While at it, I noticed that the certificate for
https://www.saastopankki.fi/ is an OV cert whose O field says
"Saastopankkiliitto osk". However, according to
https://tietopalvelu.ytj.fi/yritystiedot.aspx?yavain=25460&tarkiste=F663C7B776290379F1DAB6A4E251EE3FA727742A
, the trade name of the entity is "Säästöpankkiliitto osk". It also
has parallel trade names "Sparbanksförbundet anl" (Swedish translation
of the primary name) and "Savings Banks' Union Coop" (English
translation of the primary name) and auxiliary trade names
"Säästöpankkikeskus" and "Sparbankscentralen". But no
"Saastopankkiliitto osk".

While I don't think there is any risk of confusion in this particular
case[1], I'm wondering: What in the Baseline Requirements authorizes
DigiCert to omit the diaereses from the trade name?

The Baseline Requirements have this to say: "If present, the
subject:organizationName field MUST contain either the Subject’s name
or DBA as verified under Section 3.2.2.2. The CA may include
information in this field that differs slightly from the verified
name, such as common variations or abbreviations, provided that the CA
documents the difference and any abbreviations used are locally
accepted abbreviations; e.g., if the official record shows “Company
Name Incorporated”, the CA MAY use “Company Name Inc.” or “Company
Name”."

The variation covered by the example would have authorized the use of
the abbreviation "osk" had the registered name contained "osuuskunta"
(but it contained "osk" to begin with) or to drop "osk".

Is it documented anywhere what transformations other than ones that
are analogous to transforming "Incorporated" to "Inc." (or dropping
it) are acceptable as differing "slightly"? In the Finnish language, ä
and ö are considered to be distinct letters from a and o (so distinct
that they sort to the end of the alphabet), so from that perspective,
one could argue that the transformation is not "slight" for trade
names themselves even though it is customary for transforming trade
names into domain names[1].

Clearly, this isn't a matter of technical limitation, because DigiCert
was able to put "Ålandsbanken Abp" in the O field of the cert for
https://www.alandsbanken.fi/ .

[1] https://www.saastopankki.fi/ is the primary address to which
http://säästöpankki.fi/ (but not https!) redirects. Web site operators
in Finland generally prefer interoperability with non-IDN-cabable
usage over correct spelling.

-- 
Henri Sivonen
hsivo...@hsivonen.fi
https://hsivonen.fi/
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