Section 9.2.1 of the EVGLs is stricter, only permitting abbreviations. If
this were an EV cert I would argue that it was misissued.

On Mon, Apr 23, 2018 at 12:13 PM, Ryan Sleevi via dev-security-policy <
[email protected]> wrote:

> On Mon, Apr 23, 2018 at 1:11 PM, Henri Sivonen via dev-security-policy <
> [email protected]> wrote:
>
> > First, it seems to me that the Baseline Requirements allow
> > transformations of the organization's name only if the CA documents
> > such transformations. I am unable to find such documentation in
> > DigiCert's CP and CPS documents. Am I missing something?
> >
>
> At present, these are not required to be in the public documentation.
> Merely, the requirement is that the CA "documents" - i.e. it is presently
> acceptable to only include this documentation in information provided to
> the auditors.
>
>
> > Second, while verifying that the applicant indeed represents a
> > specific real organization is a difficult problem, in the case where
> > the country that the certificate designates operates an
> > online-queryable database of registered businesses, associations,
> > etc., it should be entirely feasible to eliminate the failure mode
> > where the certificate's organization field is (absent documented
> > transformations permitted under the Baseline Requirements) not
> > canonically equivalent (in the Unicode sense) to the name of any
> > organization registered in the country that the certificates
> > designates. That (inferring from the certificate for
> > www.alandsbanken.fi) there isn't technical process that would by
> > necessity remove diacritical marks from the organization field and
> > that the certificate for www.saastopankki.fi has them removed is
> > strongly suggestive that DigiCert's process for validating
> > Finland-based organization does not include as a mandatory part either
> > the retrieval of the organization's name via an online API to the
> > business registry or a human CA representative copying and pasting the
> > organization's name from a browser view to the business registry.
> >
>
> The Baseline Requirements do not dictate the datasource used in various
> jurisdictions. Thus even when there is a canonical source through
> legislation, the BRs do not require its use.
>
>
> >  I wonder: When a given country
>
> has an online-queryable business registry, why isn't it either
> > recommended or required to import names digitally from the business
> > registry into certificates? Such practice would eliminate the failure
> > mode of the certificate designating a name that doesn't match any
> > entry in the business registry for such country. (Obviously, if it was
> > _required_, the BRs would need to include a list of countries whose
> > business registry is considered online-queryable in the sense that the
> > requirement would apply, but unwillingness to maintain such a list
> > does not explain why it isn't even recommended.)
> >
>
> "Recommended" is pointless. Required is the only thing that makes sense,
> and the complexities and overhead involved precisely explain why it isn't
> required.
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