Guys.
I am not an expert on all this but do have some experience so hopefully the
following comments might useful.

1) The EU has a number of directives in place that require members of the EU
community to make specific provisions within local legislation. The basic
thrust of the legislation in to make digital certificates and electronic
signatures legally admissible. Most EU countires have now completed the
necessary local law changes but be aware that being compliant with local
Digital Signature legislation does not necessarily mean that a CA that
claims compliance is also operating at a WebTrust equivalent level.

2) There are requirements on member states (countries) to place some control
over commercial certificate providers but the precise nature of this in each
country is extremely variable. In some countries I believe that you
literally just need to register so it really provides no judgement regarding
the fitness of the organisation to run a CA.

Controls also vary depending upon whether a CA claims to issue Qualified
Certificates or not. The requirements for CAs issuing non-qualified
certificates can be much much lower.

3) In the UK (where I live so I know it best) we have something called
t-Scheme which is a true independent certification body. It basically sets
down a bench mark that has to be achieved to gain the Government seal of
approval. It requires a detailed assessment be completed covering
operational processes and business providence (e.g. financial stability
etc). It basically requires an organisation to be operating with ISO9001
(quality management), BS17799 (information security management) and then a
set of PKI specific items (such as adequate CP & CPS). In my view it is a
very similar approach to WebTrust.

Having said that it is possible to get t-Scheme approval for just an RA
process so you do need to understand the certification process in order for
it to be of value.

4) The equivalent body in Germany appears to be RegTP
(http://www.regtp.de/en/index.html) but I am not sure exactly what their
levels are. I think it would be wise to find out before just assuming that
because its a national register it is broadly equivalent to WebTrust, I am
pretty sure this is not the case in all countries. Having said that German
legislation is usually more rather than less ;-) so it might well be.

5) I cannot see t-Systems or Deutsche Telekom on the RegTP list and I would
have thought that any CA where the CP and CPS were not already in place
would be unlikely to meet the WebTrust requirement so by your current
benchmark would not be compliant. I am not saying that this specific
organisation is not suitable, just that at present the evidence doesn't
really suggest that they are at an equivalent WebTrust level.

6) I think if you decide to accept national accreditation bodies (which I
personally think is a good thing) some due-diligence is performed to ensure
that they are broadly equivalent to the WebTurst model as some will
undoubtedly have different levels, some which might be acceptable, some not.

I also think that a simple email from the company saying that they have a
specific accreditation is not acceptable (remember addding to the trusted
roots is quite important). They should provide a registration number that
covers a specific CA and this should then be checked by the body themsleves.
I would also have thought that the national bodies would be prepared to
support this activity as it helps increase their profile and value to the CA
operators who often have to pay quite a lot of cash to go through and
maintain their accreditation. They might even help with a comparison with
WebTrust.

Hope this helps
Mark Hobbs.


-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED] Behalf Of Nelson B
Sent: 22 December 2004 00:38
To: [email protected]
Subject: Re: New CA cert request from T-Systems


Frank Hecker wrote:

> The main issue with T-Systems is that they are not WebTrust audited, but
> they have been certified for compliance with the German Digital
> Signature Act.

By whom?  Who so certifies?

 > I'm not personally familar with how the requirements of
> this act compare to the WebTrust criteria, and therefore I don't know if
> this would satisfy the "WebTrust-equivalent" requirement. If any of you
> know more about this please post a comment in the bug above.

My guess would be that a CA that has been certified BY THE GERMAN GOVERNMENT
for compliance with their laws would be suitable for inclusion in mozilla
as an EMAIL CA only.

--
Nelson B
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