On briefly reviewing CA's Certificate Policies and Audits at random a few 
issues arose in respect to CCADB policy. My intent here isn't to highlight 
a specific CA at fault, but to note that there seems to be a theme of these 
policies not being adhered to. To that end while I'm talking about a 
specific CA in each issue, it impacts more than just one.

*CCADB Policy 5.1: Audit Statement Content*
Since version 1.2 effective February 15, 2023 there has been this language 
affecting audit reports:
- List of the CA Owner's applicable policy documents (with version numbers 
and publication dates) referenced during the audit;

As an example if we look at ACCV's TLS BR audit from 2023-06-28 
<https://cpa.cpacanada.ca/GenericHandlers/CPACHandler.ashx?AttachmentID=c12446f0-0161-4b71-87e4-299c3f86da71>
 
they mention: "ACCV’s Certification Practice Statement (CPS) – v4.0.11; and"

Now, this is compatible with the baseline requirements that don't impose 
the publication date requirement but not CCADB policy. I am under the 
impression that audits are automatically checked via the Audit Letter 
Validation process, how does this function in practice and does it need 
updated?

As an aside it seems ACCV have an updated CPS that isn't included in their 
CCADB record? The record points at a 4.0.13 CPS, while the website 
<https://www.accv.es/en/quienes-somos/practicas/> has a 5.0.2. Please be 
advised that minotaurs may be present if attempting to find this page on 
your own.

*Authoritative Language*
Since CCADB Policy 1.0 there has been wording to the effect of:
As of June 1 2017, CAs must provide English versions of any Certificate 
Policy and Certification Practice Statement documents which are not 
originally in English, with version numbers matching the document they are 
a translation of. The English version is not required to be authoritative 
in all cases of dispute, but the CA must attest that the translation is not 
materially different to the original.

With that in mind and with Actalis as an example how does this CPS 
<https://www.actalis.it/documents/archive/en/cps-ssl/2023/cps-5-13-en.aspx> 
comply:
1.2 Document Identification
This document is the Certification Practice Statement (CPS) applying to SSL 
Server and Code Signing certificates issued by Actalis S.p.A. Version and 
time of last revision are indicated on the first page. This document is 
published on Actalis’ web site in two languages: Italian and English. In 
the event of any inconsistency between the two versions, the Italian 
version takes precedence.

What is the actual process for checking certificate policies against CCADB 
policy? I was checking a few policies for their 1.4.2 text and stumbled on 
these so there are doubtless more issues...

- Wayne

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