[Top posting because previous post did]

As a relying party and a subscriber of some certificates, I would
consider each of the following combinations as something that should be
both permitted and useful under any future rules, even if the current
BRs don't allow it.

1. O=Actual Org name and OU=An actual company name for a division that
  is not obviously misleading, for example "HQ", "Accounting", "East
  campus", "Virginia servers", even if there is no direct way for any
  regular CA to verify the reality at time of issuance (will that
  certificate actually be used only at the company HeadQuarters?  Does
  the organization actually have an accounting department other than an
  old shoe-box filled with receipts, do they really have any servers in
  either of the Virginia states?).

2. O=Actual Org name, OU=Actual company division, GivenNameEtc=An actual
  person in that division.

3. O=Actual Org name, OU=Actual company division, No specific individual
  listed because certificate is for entire division.

4. OU=Domain Validated or OU=Extended Validation etc. to indicate the
  level of validation to relying parties that lack the skills to extract
  this from the more formal fields such as policy OIDs.  While this is
  not in itself the subject identity, it is a hierarchical part of a
  structured designation of the subject, similar to adding ST=California
  to a DN that already contains L=Los Angeles and C=US.

5. 1, 2 or 3 combined with 4

The following would not be allowed:

6. OU=Google when the subject is not part of that company and has no
  rights to that trademark.

7. OU=Ministry of Defence when the subject is not a (quasi) government
  that could have such.

The following would be routinely revoked as no-longer-valid-but-not-
a-CA-incident if later discovered.  (Similar to the BR rules about a
subscriber loosing their legal domain control during certificate

8. OU="Virginia servers" when it is found that the subject owns or
  operates no servers in the Virginia States.  Further sanctions against
  subject would depend if the certificate was ever used elsewhere and if
  the subject had actual servers in Virginia at a different time and
  used the cert only for those.

9. Similar to 8 but for other such cases, see 1. for examples.

On 01/11/2019 17:31, Jeremy Rowley wrote:
My view is that the OU field is a subject distinguished name field and that a 
CA must have a process to prevent unverified information from being included in 
the field.

Subject Identity Information is defined as information that identifies the 
Certificate Subject.

I suppose the answer to your question depends on a) what you consider as 
information that identifies the Certificate Subject and b) whether the process 
required establishes the minimum relationship between that information and your 
definition of SII.

From: Ryan Sleevi <r...@sleevi.com>
Sent: Friday, November 1, 2019 10:11 AM
To: Jeremy Rowley <jeremy.row...@digicert.com>
Cc: mozilla-dev-security-policy <mozilla-dev-security-pol...@lists.mozilla.org>
Subject: Re: Certificate OU= fields with missing O= field

Is your view that the OU is not Subject Identity Information, despite that 
being the Identity Information that appears in the Subject? Are there other 
fields and values that you believe are not SII? This seems inconsistent with, the section in which this is placed.

As to the <domain>.com in the OU, also prohibits this:
CAs SHALL NOT include a Domain Name or IP Address in a Subject attribute except 
as specified in Section or Section

On Fri, Nov 1, 2019 at 8:41 AM Jeremy Rowley via dev-security-policy 
A mistake in the BRs (I wrote the language unfortunately so shame on me for not 
matching the other sections of org name or the given name). There's no 
certificate that ever contains all of these fields. How would you ever have 

There's no requirement that the OU field information relate to the O field 
information as long as the information is verified.

-----Original Message-----
From: dev-security-policy 
 On Behalf Of Alex Cohn via dev-security-policy
Sent: Friday, November 1, 2019 9:13 AM
To: Kurt Roeckx <k...@roeckx.be<mailto:k...@roeckx.be>>
Cc: Matthias van de Meent 
<matthias.vandeme...@cofano.nl<mailto:matthias.vandeme...@cofano.nl>>; MDSP 
Subject: Re: Certificate OU= fields with missing O= field

On Fri, Nov 1, 2019 at 5:14 AM Kurt Roeckx via dev-security-policy 

On Fri, Nov 01, 2019 at 11:08:23AM +0100, Matthias van de Meent via 
dev-security-policy wrote:

I recently noticed that a lot of leaf certificates [0] have
organizationalUnitName specified without other organizational
information such as organizationName. Many times this field is used
for branding purposes, e.g. "issued through <someone's kpi manager>"
or "SomeBrand SSL".

BR v1.6.6 § has guidance on usage of the OU field: "The
CA SHALL implement a process that prevents an OU attribute from
including a name, DBA, tradename, trademark, address, location, or
other text that refers to a specific natural person or Legal Entity
unless the CA has verified this information in accordance with
Section 3.2 and the Certificate also contains
subject:organizationName, , subject:givenName, subject:surname,
subject:localityName, and subject:countryName attributes, also
verified in accordance with Section"

As the organizationName and other related attributes are not set in
many of those certificates, even though e.g. "COMODO SSL Unified
Communications" is a very strong reference to Sectigo's ssl branding
& business, I believe the referenced certificate is not issued in
line with the BR.

Is the above interpretation of BR section correct?

That OU clearly doesn't have anything to do with the subject that was
validated, so I also consider that a misissue.


A roughly-equivalent Censys.io query, excluding a couple other unambiguous "domain 
validated" OU values: "not _exists_:
parsed.subject.organization and _exists_:
parsed.subject.organizational_unit and not
parsed.subject.organizational_unit: "Domain Control Validated" and not
parsed.subject.organizational_unit: "Domain Validated Only" and not
parsed.subject.organizational_unit: "Domain Validated" and
validation.nss.valid: true" returns 17k hits.

IMO the "Hosted by ____.Com" certs fail - the URL of a web host is definitely 
"text that refers to a specific ... Legal Entity".

Certificate also contains subject:organizationName, ,
subject:givenName, subject:surname, subject:localityName, and
subject:countryName attributes, also verified in accordance with Section

I'm pretty sure this isn't what the BRs intended, but this appears to forbid 
issuance with a meaningful subject:organizationalUnitName unless all of the 
above attributes are populated. EVG §9.2.9 forbids including those attributes 
in the first place. Am I reading this wrong, or was this an oversight in the 


Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
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