On Tue, Oct 30, 2018 at 4:37 PM Erwann Abalea via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> > On what basis do you believe this claim is to be made? By virtue of
> > asserting qcStatement-1? If qcStatement was mis-encoded, or qcStatement-1
> > was absent, do you believe the same?
>
> qcStatement-1 is not mandatory, by law, if the policyId is QCP or QCP+, or
> if there's a matching Qualification stating that the certificate is
> Qualified. Implementing decision 2015/1505 defines the common EU rules, and
> I haven't found the specific German rules (they're asserted in the German
> TL).
> 2015/1505 can be found at
> https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015D1505
>
> My mistake was that I looked at the Sie and didn't check if there was a
> QualificationsExtension node.
>

Ah hah! Thanks for that context! That means I should re-examine the case of
Certinomis in the context of
https://groups.google.com/d/msg/mozilla.dev.security.policy/x3s3CSKdIlY/R1C4JAvOBQAJ
, since I was downplaying the significance based upon the lack of asserting
id-etsi-qcs-QcCompliance in the QCStatements, without consideration of the
Certificate Policies.

> I'm not sure the ambiguity can be as easily resolved as you suggest, given
> > the description within EN 319 412-5
>
> The weight taken by EN 319412-5 is important for the EN 319412-2
> certification, but not for the Qualified status and usage of the
> certificate (because that's a legal issue).
>

I'm not sure the issues are so easily disentangled, given the other
QCStatements supported. For example, the constitutive value of an
id-etsi-qcs-QcLimitValue. Or is the view that such issues are to be
addressed at the national level in accordance with TL maintenance?


> > Considering that even prior versions (e.g. 2.0.12) included an ASN.1
> module
> > as a normative inclusion (Annex B), I find this profoundly
> non-compelling.
> > See
> >
> https://www.etsi.org/deliver/etsi_en/319400_319499/31941205/02.01.01_60/en_31941205v020101p.pdf
> > .
>
> I was talking about draft versions. The QcType definition was SEQUENCE {
> qcType OBJECT IDENTIFIER } just before that.
>

Oh, for sure, that was in
https://www.etsi.org/deliver/etsi_en/319400_319499/31941205/02.00.12_20/en_31941205v020012a.pdf
- but even still, OIDs never aligned


> > As you dig through these versions, the adopted versions do not share the
> > ambiguity issues. You're correct that 2.2.0 formalized the corrigenda
> > against 2.2.1 to include, textually, the normative requirement of "one
> and
> > exactly one" method, but in either event, such encodings violate it
> > entirely.
>
> I agree, having the id-etsi-qct-web OID used for the statementId is a
> clear violation. I'm just pointing that this specific QCStatement was
> really stupidly defined from the start.
>

Sure. It's also unlikely that will stop anytime soon though (c.f. PSD2 in
TS 119 495, although that may be withdrawn now?
https://portal.etsi.org/webapp/workProgram/Report_Schedule.asp?WKI_ID=53961
)
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