Trust service principles and criteria for certification authorities

Trust Service Principles and
Criteria for Certification
Authorities
Version 2.0
March 2011
(Effective July 1, 2011)
(Supersedes WebTrust for Certification Authorities
Principles Version 1.0 August 2000)
Copyright  2011 by
Canadian Institute of Chartered Accountants.
All rights reserved. The Principles and Criteria may be reproduced and distributed provided that
reproduced materials are not in any way directly offered for sale or profit and attribution is given.

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AICPA/CICA Public Key Infrastructure (PKI) Assurance Task Force
Donald E. Sheehy, Deloitte & Touche, LLP Chair
Michael Greene, Ernst & Young LLP
Mark Lundin, KPMG LLP
Jeffrey Ward, Stone Carlie & Company LLC
The AICPA and CICA would like to express gratitude to the members of the Task Force and its
chair, Don Sheehy, for the knowledge they have contributed and time and effort expended to
develop the Trust Services Prinicples and Criteria for Certification Authorities. Equally
appreciated is the contribution of Reema Anand, KPMG LLP, who contributed greatly to the
knowledge of the Task Force.
Staff Contact:
Bryan Walker, CICA
EFFECTIVE DATE
These Principles and Criteria are effective for years commencing on or after July 1, 2011
although earlier implementation is encouraged.

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Table of Contents
Effective date .................................................................................................................................. 2
INTRODUCTION .......................................................................................................................... 6
Introduction to Trust Service Principles and Criteria for Certification Authorities Version 2.0.....6
Importance of PKI............................................................................................................................6
OVERVIEW ................................................................................................................................... 7
What is a Public Key Infrastructure?...............................................................................................7
What is a Digital Signature? ............................................................................................................9
What are the Differences Between Encryption Key Pairs and Signing Key Pairs? ......................10
What is a Certification Authority?.................................................................................................11
What is a Registration Authority?..................................................................................................11
What is the Impact of an External RA? .........................................................................................13
What is an Extended Validation Certificate?.................................................................................14
What is a Certification Practice Statement and a Certificate Policy?............................................14
What are the Hierarchical and Cross-Certified CA Models?........................................................14
What is the Impact of Subordinate CAs?.......................................................................................15
What are Some of the Business Issues Associated with CAs? ......................................................16
PRINCIPLES AND CRITERIA FOR CERTIFICATION AUTHORITIES................................ 17
Certification Authorities Principles ...............................................................................................17
CA Business Practices Disclosure ........................................................................................ 17
Service Integrity.................................................................................................................... 17
CA Environmental Controls ................................................................................................. 18
Intended Use of the Trust Services Principles and Criteria ...........................................................19
TRUST SERVICE PRINCIPLES AND CRITERIA FOR CERTIFICATION AUTHORITIES 20
1. CA BUSINESS PRACTICES DISCLOSURE ............................................................................ 20

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1.1 Certification Practice Statement (CPS) ...................................................................20
1.2 Certificate Policy (if applicable) .............................................................................20
2. CA BUSINESS PRACTICES MANAGEMENT ...................................................21
2.1 Certificate Policy Management (if applicable) .......................................................21
2.2 Certification Practice Statement Management ........................................................21
2.3 CP and CPS Consistency (if applicable) .................................................................22
3. CA ENVIRONMENTAL CONTROLS..................................................................23
3.1 Security Management..............................................................................................23
3.2 Asset Classification and Management ....................................................................24
3.3 Personnel Security...................................................................................................25
3.4 Physical and Environmental Security......................................................................27
3.5 Operations Management..........................................................................................29
3.6 System Access Management...................................................................................30
3.7 Systems Development and Maintenance.................................................................33
3.8 Business Continuity Management...........................................................................34
3.9 Monitoring and Compliance....................................................................................36
3.10 Audit Logging .........................................................................................................37
4. CA KEY LIFE CYCLE MANAGEMENT CONTROLS.......................................41
4.1 CA Key Generation.................................................................................................41
4.2 CA Key Storage, Backup and Recovery .................................................................43
4.3 CA Public Key Distribution ....................................................................................43
4.4 CA Key Usage.........................................................................................................44
4.5 CA Key Archival and Destruction ..........................................................................45
4.6 CA Key Compromise ..............................................................................................46
4.7 CA Cryptographic Hardware Life Cycle Management...........................................47

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4.8 CA Key Escrow (if applicable) ...............................................................................48
5. SUBSCRIBER KEY LIFE CYCLE MANAGEMENT CONTROLS....................50
5.1 CA-Provided Subscriber Key Generation Services (if supported)..........................50
5.2 CA-Provided Subscriber Key Storage and Recovery Services (if supported) ........50
5.3 Integrated Circuit Card (ICC) Life Cycle Management (if supported)...................52
5.4 Requirements for Subscriber Key Management .....................................................55
6. CERTIFICATE LIFE CYCLE MANAGEMENT CONTROLS............................57
6.1 Subscriber Registration ...........................................................................................57
6.2 Certificate Renewal (if supported) ..........................................................................59
6.3 Certificate Rekey.....................................................................................................60
6.4 Certificate Issuance .................................................................................................61
6.5 Certificate Distribution............................................................................................62
6.6 Certificate Revocation.............................................................................................63
6.7 Certificate Suspension (if supported)......................................................................64
6.8 Certificate Validation ..............................................................................................65
7. SUBORDINATE CA CERTIFICATE LIFE CYCLE MANAGEMENT
CONTROLS............................................................................................................67
7.1 Subordinate CA Certificate Life Cycle Management .............................................67
APPENDIX A................................................................................................................................69
§1 RFC 3647 69
§2 RFC 2527 76
§3 WebTrust for CAs v1................................................................................................................80

INTRODUCTION
Introduction to Trust Service Principles and Criteria for Certification Authorities Version 2.0
This document provides a framework for third party assurance providers to assess the adequacy and
effectiveness of the controls employed by Certification Authorities (CAs). As a result of the technical
nature of the activities involved in securing e-commerce transactions, this document also provides a brief
overview of public key infrastructure (PKI) using cryptography and trusted third-party concepts.
This document replaces Version 1.0 of the AICPA/CICA WebTrust Program for Certification Authorities
that was issued in August 2000. Unlike Version 1.0 that was intended to be used by licensed WebTrust
practitioners only, this version is regarded as “open-source” and can be used in the conduct of any
assurance engagement, internal or external, by any third-party service provider. It also represents an
effective benchmark for CAs to conduct self-assessments. The public accounting profession has
continued to play its role, with an intent to increase consumer confidence in the application of PKI
technology by establishing a basis for providing third party assurance to the assertions made by CAs.
This document was developed by a CICA/AICPA Task Force using ISO 21188 “Public Key Policy and
Practices Framework” and Version 1.0 of the AICPA/CICA WebTrust Program for Certification
Authorities.
Input and approval was also obtained from the Certification Authority Browser Forum (CA/Browser
Forum – see www.cabforum.org) for the content and control activities contained in this framework. The
CA/Browser Forum was formed among certification authorities (CAs) and vendors of Internet browser
software and other applications. This voluntary organization has worked collaboratively in defining
guidelines and means of implementation for the Extended Validation (EV) SSL Certificate standard as a
way of providing a heightened security for Internet transactions and creating a more intuitive method of
displaying secure sites to Internet users.
The Principles and Criteria for Certification Authorities are consistent with standards developed by the
American National Standards Institute (ANSI), International Organization for Standardization (ISO), and
Internet Engineering Task Force (IETF). The Principles and Criteria are also consistent with the practices
established by the CA Browser Forum (see www.cabforum.org).
Importance of PKI
PKI provides a means for relying parties (meaning, recipients of certificates who act in reliance on those
certificates and/or digital signatures verified using those certificates) to know that another individual’s or

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entity’s public key actually belongs to that individual/entity. CA organizations and/or CA functions have
been established to address this need.
Cryptography is critical to establishing secure e-commerce. However, it has to be coupled with other
secure protocols in order to provide a comprehensive security solution. Several cryptographic protocols
require digital certificates (in effect, electronic credentials) issued by an independent trusted third party
(the CA) to authenticate the transaction. CAs have assumed an increasingly important role in secure e-
commerce. Although there is a large body of existing national, international, and proprietary standards
and guidelines for the use of cryptography, the management of digital certificates, and the policies and
practices of CAs, these standards have not been applied or implemented uniformly.
This version is titled the Trust Services Principles and Criteria for Certification Authorities Version 2.0.
These Principles and Criteria are intended to address user (meaning, subscriber and relying party) needs
and concerns and are designed to benefit users and providers of CA e-commerce assurance services by
providing a common body of knowledge that is communicated to such parties.
OVERVIEW
What is a Public Key Infrastructure?
With the expansion of e-commerce, PKI is growing in importance and will continue to be a critical
enterprise security investment. PKI enables parties to an e-commerce transaction to identify one another
by providing authentication with digital certificates, and allows reliable business communications by
providing confidentiality through the use of encryption, and authentication data integrity and a reasonable
basis for nonrepudiation through the use of digital signatures.
PKI uses public/private-key pairs—two mathematically related keys. Typically, one of these keys is
made public, by posting it on the Internet for example, while the other remains private. Public-key
cryptography works in such a way that a message encrypted with the public key can only be decrypted
with the private key, and, conversely, a message signed with a private key can be verified with the public
key. This technology can be used in different ways to provide the four ingredients required for trust in e-
commerce transactions, namely: confidentiality, authentication, integrity, and nonrepudiation.
Using PKI, a subscriber (meaning, an end entity (or individual) whose public key is cryptographically
bound to his or her identity in a digital certificate) has an asymmetric cryptographic key pair (meaning, a
public key and a private key). The subscriber’s private key must be kept secret, whereas the public key
may be made widely available, usually presented in the form of a digital certificate to ensure that relying
parties know with confidence the identity to which the public key belongs. Using public key

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cryptography, the subscriber could send a message signed with his or her private key. The signature can
be validated by the message recipient using the subscriber’s public key. The subscriber could also
encrypt a message using the recipient’s public key. The message can be decrypted only with the
recipient’s private key.
A subscriber first obtains a public/private key pair (generated by the subscriber or for the subscriber as a
service). The subscriber then goes through a registration process by submitting their public key to a
Certification Authority or a Registration Authority (RA), which acts as an agent for the CA. The CA or
RA verifies the identity of the subscriber in accordance with the CA’s established business practices (that
may be contained in a Certification Practice Statement), and then issues a digital certificate. The
certificate includes the subscriber’s public key and identity information, and is digitally signed by the CA,
which binds the subscriber’s identity to that public key. The CA also manages the subscriber’s digital
certificate through the certificate life cycle (meaning, from registration through revocation or expiration).
In some circumstances, it remains important to manage digital certificates even after expiry or revocation
so that digital signatures on stored documents held past the revocation or expiry period can be validated at
a later date.
The following diagram illustrates the relationship between a subscriber’s public and private keys, and
how they are used to secure messages sent to a relying party.
Unique
mathematical
relationship
Private
key
Public
key
Message
encrypted
with public
key
Can only be
opened with
private key
A transaction submitted by a customer to an online merchant via the Internet can be encrypted with the
merchant’s public key and therefore can only be decrypted by that merchant using the merchant’s private
key—ensuring a level of confidentiality. Confidentiality can also be achieved through the use of Secure
Socket Layer (SSL), Secure/Multipurpose Internet Mail Extensions (S/MIME), and other protocols, such
as Secure Electronic Transaction (SET).

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What is a Digital Signature?
Digital signatures can be used to provide authentication, integrity, and nonrepudiation. Generally
speaking, if a customer sends a digitally signed message to a merchant, the customer’s private key is used
to generate the digital signature and the customer’s public key can be used by the merchant to verify the
signature. The mathematical processes employed are somewhat different depending on the kind of
asymmetric cryptographic algorithm employed. For example, the processes are slightly different for
reversible algorithms (i.e., those which can be readily used to support digital signatures as well as
encryption) such as Rivest Shamir Adleman (RSA) and irreversible algorithms such as the Digital
Signature Algorithm (DSA).
The following example illustrates the digital signature generation and verification process for a reversible
asymmetric cryptographic algorithm (such as RSA). Suppose a customer wants to send a digitally signed
message to a merchant. The customer runs the message through a hash function (meaning, a
mathematical function that converts a message into a fixed length block of data, the hash, in a fashion
such that the hash uniquely reflects the message – in effect, it is the message’s “fingerprint”). The
customer then transforms the hash using the algorithm and the customer’s private key to create the digital
signature which is appended to the message. A header is also appended to the message, indicating the
merchant’s email address, the sender’s email address, and other information such as the time the message
is sent. The message header, the message itself, and the digital signature are then sent to the merchant.
The customer can optionally send his/her public key certificate to the merchant in the message itself. All
of this is usually done by the e-mail software in such a way that the process is transparent to the user.
The following diagram illustrates the process of using a subscriber’s key pair to ensure the integrity and
authenticity of a message sent by the customer (subscriber) to a merchant.
private
key
public
key
MessageMessage
Creates hash and
transforms with private
key to form digital
signature
Customer Merchant
+
Header
+
Digital Signature
Transforms hash with
public key, recreates
hash and compares to
validate digital signature
Header
+
+
Digital Signature
Customer’s
Customer’s
To determine whether the message came from the customer (meaning, authentication) and to determine
whether the message has not been modified (meaning, integrity), the merchant validates the digital
signature. To do so, the merchant must obtain the customer’s public key certificate. If the customer did
not send his or her public key certificate as part of the message, the merchant would typically obtain the

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customer’s public key certificate from an online repository (maintained by the CA or another party acting
as the agent of the CA, or any other source even if unrelated to the CA). The merchant then validates that
the customer’s digital certificate (containing the customer’s public key) was signed by a recognized
Certification Authority to ensure that the binding between the public key and the customer represented in
the certificate has not been altered. Next, the merchant extracts the public key from the certificate and
uses that public key to transform the digital signature to reveal the original hash. The merchant then runs
the message as received through the same hash function to create a hash of the received message. To
verify the digital signature, the merchant compares these two hashes. If they match, then the digital
signature validates and the merchant knows that the message came from the customer and it was not
modified from the time the signature was made. If the hashes do not match, then the merchant knows that
the message was either modified in transit or the message was not signed with the customer’s private key.
As a result, the merchant cannot rely on the digital signature.
Digital signatures can also be used to provide a basis for nonrepudiation so that the signer cannot readily
deny having signed the message. For example, an online brokerage customer who purchases one
thousand shares of stock using a digitally signed order via the Internet should have a difficult task if he or
she later tries to deny (meaning, repudiate) having authorized the purchase.
What are the Differences Between Encryption Key Pairs and Signing Key Pairs?
As stated earlier, establishing a reasonable basis for nonrepudiation requires that the private key used to
create a digital signature (meaning, the signing private key) be generated and stored securely under the
sole control of the user. In the event a user forgets his or her password or loses, breaks, or destroys
his/her signing private key, it is acceptable to generate a new signing key pair for use from that point
forward with minimal impact to the subscriber. Previously signed documents can still be verified with the
user’s old signature verification public key. Documents subsequently signed with the user’s new signing
private key must be verified with the user’s new signature verification public key.
Extra care is required to secure the Certification Authority’s signing private key, which is used for signing
user certificates. The trustworthiness of all certificates issued by a CA depends upon the CA’s protecting
its private signing key. CAs securely back up their private signing key(s) for business continuity purposes
to allow the CA to continue to operate in the event that the CA’s private signing key is accidentally
destroyed (but not compromised) as a result of hardware failure, for example. Except for CA business
continuity purposes, there are generally no technical or business reasons to back up a signing private key.
On the other hand, and as cited earlier, it is often desirable that a key pair used for encryption and
decryption be securely backed up to ensure that encrypted data can be recovered when a user forgets his

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or her password or otherwise loses access to his or her decryption key. This is analogous to requiring that
the combination to a safe be backed up in case the user forgets it, or becomes incapacitated. As a result, a
PKI typically requires two key pairs for each user: one key pair for encryption and decryption and a
second key pair for signing and signature verification.
What is a Certification Authority?
In order for these technologies to enable parties to securely conduct e-commerce, one important question
must be answered. How will we know in the digital world that an individual’s public key actually
belongs to that individual? A digital certificate, which is an electronic document containing information
about an individual and his or her public key, is the answer. This document is digitally signed by a
trusted organization referred to as a Certification Authority (CA). The basic premise is that the CA is
vouching for the link between an individual’s identity and his or her public key. The Certification
Authority provides a level of assurance that the public key contained in the certificate does indeed belong
to the entity named in the certificate. The digital signature placed on the public key certificate by the CA
provides the cryptographic binding between the entity’s public key, the entity’s name, and other
information in the certificate, such as a validity period. For a relying party to determine whether the
certificate was issued by a legitimate CA, the relying party must verify the issuing CA’s signature on the
certificate. The public keys of many common Root CAs (as later defined) are pre-loaded into standard
Web browser software (for example, Netscape Navigator or Microsoft Internet Explorer). This allows the
relying party to verify the issuing CA’s signature using the CA’s public key to determine whether the
certificate was issued by a trusted CA.
The purpose of a CA is to manage the certificate life cycle, which includes generation and issuance,
distribution, renewal and rekey, revocation, and suspension of certificates. The CA frequently delegates
the initial registration of subscribers to Registration Authorities (RAs) which act as agents for the CA. In
some cases, the CA may perform registration functions directly. The CA is also responsible for providing
certificate status information though the issuance of Certificate Revocation Lists (CRLs) and/or the
maintenance of an online status checking mechanism. Typically, the CA posts the certificates and CRLs
that it has issued to a repository (such as an online directory) which is accessible to relying parties.
What is a Registration Authority?
A Registration Authority (RA) is an entity that is responsible for the identification and authentication of
subscribers, but does not sign or issue certificates. In some cases, the CA performs the subscriber
registration function internally. In other cases, the CA might delegate the RA function to external
registration authorities (sometimes referred to as Local Registration Authorities or LRAs) that may or

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may not be part of the same legal entity as the CA. In still other cases, a customer of a CA (for example,
a company) may arrange with that CA to perform the RA function itself or use its agent.
The initial registration process for a subscriber is as follows, though the steps may vary from CA to CA
and will also depend upon the Certificate Policy under which the certificate is to be issued. The
subscriber first generates his or her own public/private key pair. (In some implementations, a CA may
generate the subscriber’s key pair and securely deliver it to the subscriber, but this is normally done only
for encryption key pairs, not signature key pairs.) Then the subscriber produces proof of identity in
accordance with the applicable Certificate Policy requirements and demonstrates that he or she holds the
private key corresponding to the public key without disclosing the private key (typically by digitally
signing a piece of data with the private key, with the subscriber’s digital signature then verified by the
CA). Once the association between a person and a public key is verified, the CA issues a certificate. The
CA digitally signs each certificate that it issues with its private key to provide the means for establishing
authenticity and integrity of the certificate.
The CA then notifies the subscriber of certificate issuance and gives the subscriber an opportunity to
review the contents of the certificate before it is made public. Assuming the subscriber approves the
accuracy of the certificate, the subscriber will publish the certificate and/or have the CA publish it and
make it available to other users. A repository is an electronic certificate database that is available online.
The repository may be maintained by the CA or a third party contracted for that purpose, or by the
subscriber, or by any other party. Subscribers may obtain certificates of other subscribers and certificate
status information from the repository. For example, if a subscriber’s certificate was revoked, the
repository would indicate that the subscriber’s certificate has been revoked and should not be relied upon.
The ability to update the repository is typically retained by the CA. Subscribers and other relying parties
would have read-only access to the repository. Because the certificates stored in the repository are
digitally signed by the CA, they cannot be maliciously changed without detection, even if someone were
to hack into the repository.
The following diagram illustrates the relationship between the subscriber and the RA and CA functions.

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Subscriber CARA
Repository
Relying
Party
Provides proof
of identity
Registration function
(performed by CA
or separate RA)
Verifies Subscriber’s
identity
Issues certificate
and posts in
repository
May be housed
by CA or other
entity
Binds public key
to Subscriber
Validates CA’s
signature on the
Subscriber’s
certificate
What is the Impact of an External RA?
External registration authorities are required to comply with the relevant provisions of the CA’s business
practices disclosures, often documented in a Certification Practice Statement and applicable Certificate
Policy(s). In performing a WebTrust for Certification Authorities engagement, the practitioner must
consider how the CA handles the RA function and whether the RA function is within the scope of the
examination. For example, a CA that provides CA services to several banks, might delegate the
subscriber registration function to RAs that are specifically designated functional groups within each
bank. The functions performed by these specific groups would typically be outside the scope of the
WebTrust for Certification Authorities examination performed for the CA. In this case management’s
assertion should specify those aspects of the registration process that are not handled by the CA. There
may be scenarios, however, where the CA exercises extensive monitoring controls (including onsite
audit) over all aspects of the RA operations and the CA is willing to assert to the effectiveness of the
controls performed by the external RAs and include the RA operations in the examination. In these rare
situations, the CA and the auditor need to agree in advance with this approach, including the extent and
sufficiency of controls being exercised.
External RAs could be examined and reported upon separately from the CA, using the relevant criteria
contained in this Trust Services Principles and Criteria for Certification Authorities Version 2.0.
Illustrative reports for these types of examinations will be the subject of future guidance.

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What is an Extended Validation Certificate?
When a Certification Authority performs additional steps to authenticate the entity to which certificates
are being issued, the certificates issued are differentiated and issued as extended validation certificates.
These certificates provide even more assurance regarding the identity of the Web site owner.
“Extended Validation SSL (EV SSL) Certificates build on the existing SSL certificate format, but provide
an additional layer of protection in a strictly defined issuance process created to ensure that the certificate
holder is who they claim to be. To ensure the ongoing integrity of the process, revocation measures are
specified that allow for the quick and effective revocation of improperly issued or misused certificates.
Leading Relying-Party Application Software Suppliers support EV SSL, which allows the browser to
display the verified identity of the Web site owner to the user.”1
What is a Certification Practice Statement and a Certificate Policy?
A Certification Practice Statement (CPS) is a statement of the practices which a Certification Authority
employs in issuing and managing certificates. A Certificate Policy (CP) is a named set of rules that
indicates the applicability of a certificate to a particular community and/or class of application with
common security requirements. For example, a particular Certificate Policy might indicate the
applicability of a type of certificate to the authentication of electronic data interchange transactions for the
trading of goods within a given price range.
What are the Hierarchical and Cross-Certified CA Models?
CAs may be linked using two basic architectures or a hybrid of the two: (1) hierarchical and (2) cross-
certified (shared trust). In a hierarchical model, a highest level (or “Root”) CA is deployed and
subordinate CAs may be set up for various business units, domains or communities of interest. The Root
CA validates the subordinate CAs, which in turn issue certificates to lower tier CAs or directly to
subscribers. Such a Root CA typically has more stringent security requirements than a subordinate CA.
Although it is difficult for an attacker to access the Root CA (which in some implementations is only on-
line in the rare event that it must issue, renew, or revoke subordinate CA certificates), one drawback to
this model is that the Root CA represents a single point of failure. In the hierarchical model, the Root CA
maintains the established “community of trust” by ensuring that each entity in the hierarchy conforms to a
minimum set of practices. Adherence to the established policies may be tested through audits of the
subordinate CAs and, in a number of cases, the Registration Authorities.
1 See www.cabforum.org

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The following diagram illustrates the structure and relationships between certification authorities and
subscribers operating in a hierarchical model.
In an alternative model, cross-certified CAs are built on a “peer-to-peer” model. Rather than deploying a
common Root CA, the cross-certification model shares trust among CAs known to one another. Cross-
certification is a process in which two CAs certify the trustworthiness of the other’s certificates. If two
CAs, CA1 and CA2, cross-certify, CA1 creates and digitally signs a certificate containing the public key
of CA2 (and vice versa). Consequently, users in either CA domain are assured that each CA trusts the
other and therefore subscribers in each domain can trust each other. Cross-certified CAs are not subject
to the single point of failure in the hierarchical model. However, the network is only as strong as the
weakest CA, and requires continual policing. In the cross-certified model, to establish and maintain a
community of trust, audits may be performed to ensure that each cross-certified CA conforms to a
minimum set of practices as agreed upon by the members of the community of trust.
The following diagram illustrates the structure and relationships between certification authorities and
subscribers operating in a cross-certified (shared trust) model.
CA-1, CA-2, CA-3 Cross Certify Each Other
CA-1 CA-2 CA-3
Certificate Certificate Certificate
In a hybrid model, both a hierarchical structure and cross-certification are employed. For example, two
existing hierarchical communities of trust may want to cross-certify each other, such that members of
each community can rely upon the certificates issued by the other to conduct e-commerce.
What is the Impact of Subordinate CAs?
Depending on report users’ needs, Subordinate CAs may or may not be included in the scope of
examination. It is important that the system description and assertion clearly articulate the hierarchy that
Root CA
Sub-CA Sub-CA Sub-CA

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is in scope.
What are Some of the Business Issues Associated with CAs?
Unless they are subject to governmental licensing and regulation, CAs may use different standards or
procedures to verify the identity of persons to whom they issue certificates. Thus a digital signature is
only as reliable as the CA is trustworthy in performing its functions. Consequently, a relying party needs
some way to gauge how much reliance it should place on a digital signature supported by a certificate
issued by a particular CA.
CA topology (for example, a hierarchical, cross-certified, or a hybrid model) is a developing issue.
Which model is most appropriate depends on the particular business circumstances. Although it is
important that public keys be certified, the issuance of nonstandard certificates can be a concern. For
example, if the broadly recognized International Telecommunications Union-Telecommunication
Standardization Sector’s (ITU-T) X.509 data format standard2 is not used, subscribers and relying parties
may be unable to process such certificates. Implementing the cross-certified CA model (discussed above)
would also be very difficult. For these reasons, major entities such as the U.S. and Canadian governments
are using or plan to use X.509 certificates for their internal and external activities.
2 ITU-T Recommendation X.509 (1997) was also standardized by ISO as ISO/IEC 9594-8.

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PRINCIPLES AND CRITERIA FOR CERTIFICATION AUTHORITIES
In order to be understandable to the ultimate users—the subscriber and relying party, the principles set out
in the following sections have been developed with the relying party in mind and, as a result, are intended
to be practical and nontechnical in nature.
Certification Authorities Principles
CA Business Practices Disclosure
The Certification Authority:
 Discloses its Business, Key Life Cycle Management, Certificate Life Cycle Management, and CA
Environmental Control practices in its Certification Practice Statement; and
Environmental Control policies in its Certificate Policy (if applicable).
The Certification Authority maintains effective controls to provide reasonable assurance that:
 The CA’s Certification Practice Statement is consistent with its Certificate Policy (if applicable); and
 The CA provides its services in accordance with its Certificate Policy (if applicable) and Certification
Practice Statement.
The Certification Authority must disclose its key and certificate life cycle management business and
information privacy practices. Information regarding the CA’s business practices should be made
available to all subscribers and all potential relying parties, typically by posting on its Web site. Such
disclosure may be contained in a Certificate Policy (CP) and/or Certification Practice Statement (CPS), or
other informative materials that are available to users (subscribers and relying parties).
Service Integrity
 The integrity of keys and certificates it manages is established and protected throughout their life
cycles;
 The Subscriber information is properly authenticated (for the registration activities performed by
ABC-CA); and
 Subordinate CA certificate requests are accurate, authenticated and approved.

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Effective key management controls and practices are essential to the trustworthiness of the public key
infrastructure. Cryptographic key management controls and practices cover CA key generation, CA key
storage, backup and recovery, CA public key distribution (especially when done in the form of self-signed
“root” certificates), CA key escrow (if applicable), CA key usage, CA key destruction, CA key archival,
the management of CA cryptographic hardware through its life cycle, and CA-provided subscriber key
management services (if applicable); and Strong key life cycle management controls are vital to guard
against key compromise which can damage the integrity of the public key infrastructure.
The user certificate life cycle is at the core of the services provided by the CA. The CA establishes its
standards and practices by which it will deliver services in its published CPS and Certificate Policy(s).
The user certificate life cycle includes the following:
 Registration (meaning, the identification and authentication process related to binding the individual
subscriber to the certificate);
 The renewal of certificates (if applicable);
 The rekey of certificates;
 The revocation of certificates;
 The suspension of certificates (if applicable);
 The timely publication of certificate status information (through Certificate Revocation Lists or some
form of online certificate status protocol); and
 The management of integrated circuit cards (ICCs) holding private keys through their life cycle (if
applicable).
Effective controls over the registration process are essential, as poor identification and authentication
controls jeopardize the ability of subscribers and relying parties to rely on the certificates issued by the
CA. Effective revocation procedures and timely publication of certificate status information are also
critical elements, as it is critical for subscribers and relying parties to know when they are unable to rely
on certificates that have been issued by the CA.
CA Environmental Controls
 Logical and physical access to CA systems and data is restricted to authorized individuals;
 The continuity of key and certificate management operations is maintained; and

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 CA systems development, maintenance and operations are properly authorized and performed to
maintain CA systems integrity.
The establishment and maintenance of a trustworthy CA environment is essential to the reliability of the
CA’s business processes. Without strong CA environmental controls, strong key and certificate life cycle
management controls are severely diminished in value. CA environmental controls include CPS and CP
management, security policy management, security management, asset classification and management,
personnel security, physical and environmental security of the CA facility, operations management,
system access management, systems development and maintenance, business continuity management,
monitoring and compliance, and event journaling.
The original CA Business Practices Disclosure criteria in Version 1.0 were derived primarily from the
Internet Engineering Task Force’s (IETF) Internet X.509 Public Key Infrastructure Certificate Policy and
Certification Practices FrameworkRequest For Comments Draft (RFC 2527), which has been
incorporated into Annex A of the draft ANSI X9.79 standard. Trust Services Principles and Criteria
for Certification Authorities Version 2.0 currently allows the CA to use RFC 2527, Version 1.0 of the
WebTrust for CA Criteria or RFC 3647 that was issued in November 20033. For specific key and
certificate life cycle management and CA environmental illustrative controls, in which the CA’s
implemented controls may vary depending on the CA’s business practices, such illustrative controls refer
to specifically required CA business practices disclosures included in Principle 1.
Intended Use of the Trust Services Principles and Criteria
The Trust Services Principles and Criteria for CAs can be used as a control framework to assess the
adequacy of the CA systems, policies and procedures. It provides a basis for self-assessment for either
development or maintaining strong PKI systems.
Assessors/auditors can use the framework as a benchmark for performing an internal or independent
assessment as an internal auditor, or an independent external auditor as supported by the CA/Browser
Forum. For licensed WebTrust auditors additional support is provided at www.webtrust.org.
3 In the event that a replacement for RFC 3647 is issued at a future date, that version could also be used.

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TRUST SERVICE PRINCIPLES AND CRITERIA FOR CERTIFICATION AUTHORITIES
1. CA BUSINESS PRACTICES DISCLOSURE
The Certification Authority:
Environmental Control practices in its Certification Practice Statement;
 Discloses its Business, Key Life Cycle Management, Certificate Life Cycle Management,,and CA
Environmental Control policies in its Certificate Policy (if applicable); and
 Provides services in accordance with its disclosed practices.
1.1 Certification Practice Statement (CPS)
Criteria:
The CA discloses its business practices including but not limited to the topics listed in RFC 3647, RFC 2527,
or WebTrust for Certification Authorities v1 CA Business Practices Disclosure Criteria (see Appendix A) in
its Certification Practice Statement.
1.2 Certificate Policy (if applicable)
Criteria:
The CA discloses its business practices including but not limited to the topics listed in RFC 3647, RFC 2527,
or WebTrust for Certification Authorities v1 (see Appendix A) in its Certificate Policy.

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2. CA BUSINESS PRACTICES MANAGEMENT
 The CA’s Certification Practice Statement is consistent with its Certificate Policy (if applicable); and
 The CA provides its services in accordance with its Certificate Policy (if applicable) and Certification
Practice Statement.
2.1 Certificate Policy Management (if applicable)
Criteria:
The CA maintains controls to provide reasonable assurance that its Certificate Policy (CP) management
process is effective.
Illustrative Controls:
Certificate Policy Management
1 The Policy Authority (PA) has the responsibility of defining the business requirements and policies for
using digital certificates and specifying them in a Certificate Policy (CP) and supporting agreements.
2 The PA has final authority and responsibility for specifying and approving Certificate Policy(s).
3 Certificate Policy(s) are approved by the Policy Authority in accordance with a defined review process,
including responsibilities for maintaining and tracking changes to the Certificate Policy(s).
4 A defined review process exists to assess that the Certificate Policy(s) are capable of support by the
controls specified in the CPS.
5 The PA makes available the Certificate Policies supported by the CA to Subscribers and Relying
Parties.
2.2 Certification Practice Statement Management
Criteria:
The CA maintains controls to provide reasonable assurance that its Certification Practice Statement (CPS)
management processes are effective.
Certification Practice Statement (CPS) Management
1 The PA has final authority and responsibility for approving the CA’s Certification Practice Statement
(CPS).
2 Responsibilities for maintaining the CPS have been formally assigned.

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3 The CA’s CPS is modified and approved in accordance with a defined review process.
4 The CA makes available its Certification Practice Statement (CPS) to all appropriate parties.
5 Revisions to the CA’s CPS are made available to appropriate parties.
6 The CA updates its CPS to reflect changes in the environment as they occur.
2.3 CP and CPS Consistency (if applicable)
Criteria:
The CA maintains controls to provide reasonable assurance that its Certification Practice Statement addresses
the topics included in its Certificate Policy.
CP and CPS Consistency
1 The PA is responsible for ensuring that the CA’s control processes, as stated in a Certification Practice
Statement (CPS) or equivalent, fully comply with the requirements of the CP.
2 The CA addresses the requirements of the CP when developing its CPS.
3 The CA assesses the impact of proposed CPS changes to ensure that they are consistent with the CP.
4 A defined review process exists to ensure that Certificate Policy(s) are supported by the CA’s CPS.

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3. CA ENVIRONMENTAL CONTROLS
 Logical and physical access to CA systems and data is restricted to authorized individuals;
 The continuity of key and certificate management operations is maintained; and
 CA systems development, maintenance and operations are properly authorized and performed to
maintain CA systems integrity.
3.1 Security Management
Criteria:
The CA maintains controls to provide reasonable assurance that:
 security is planned, managed and supported within the organization;
 security risks are identified and managed;
 the security of CA facilities, systems and information assets accessed by third parties is maintained; and
 the security of subscriber and relying party information is maintained when the responsibility for CA sub-
functions has been outsourced to another organization or entity.
Information Security Policy
1 An information security policy document, that includes physical, personnel, procedural and technical
controls, is approved by management, published and communicated to all employees.
2 The information security policy includes the following:
a) a definition of information security, its overall objectives and scope, and the importance of
security as an enabling mechanism for information sharing;
b) a statement of management intent, supporting the goals and principles of information security;
c) an explanation of the security policies, principles, standards and compliance requirements of
particular importance to the organization;
d) a definition of general and specific responsibilities for information security management,
including reporting security incidents; and
e) references to documentation, which supports the policy.
3 There is a defined review process for maintaining the information security policy, including
responsibilities and review dates.
Information Security Infrastructure
4 Senior management and/or a high-level management information security committee have the
responsibility to ensure there is clear direction and management support to manage risks effectively.

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5 A management group or security committee exists to co-ordinate the implementation of information
security controls and the management of risk.
6 Responsibilities for the protection of individual assets and for carrying out specific security processes
are clearly defined.
7 A management authorization process for new information processing facilities exists and is followed.
Security of Third Party Access
8 Procedures exist and are enforced to control physical and logical access to CA facilities and systems by
third parties (e.g., on-site contractors, trading partners and joint ventures).
9 If there is a business need for the CA to allow third party access to CA facilities and systems, a risk
assessment is performed to determine security implications and specific control requirements.
10 Arrangements involving third party access to CA facilities and systems are based on a formal contract
containing necessary security requirements.
Outsourcing
11 If the CA outsources the management and control of all or some of its information systems, networks,
and/or desktop environments, the security requirements of the CA are addressed in a contract agreed
upon between the parties.
12 If the CA chooses to delegate a portion of the CA roles and respective functions to another party, the
CA maintains responsibility for the completion of the outsourced functions and the definition and
maintenance of a statement of its CPS.
3.2 Asset Classification and Management
Criteria:
The CA maintains controls to provide reasonable assurance that CA assets and subscriber and relying party
information receive an appropriate level of protection based upon identified risks and in accordance with the
CA’s disclosed business practices.
1 Owners are identified for all CA assets and assigned responsibility for the protection of the assets.
2 Inventories of CA assets are maintained.

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3 The CA has implemented information classification and associated protective controls for information
based on business needs and the business impacts associated with such needs.
4 Information labeling and handling are performed in accordance with the CA’s information classification
scheme and documented procedures.
3.3 Personnel Security
Criteria:
The CA maintains controls to provide reasonable assurance that personnel and employment practices enhance
and support the trustworthiness of the CA’s operations.
1 The CA employs personnel(i.e., employees and contractors) who possess the relevant skills, knowledge
and experience required for the job function.
2 Security roles and responsibilities, as specified in the organization’s security policy, are documented in
job descriptions.
3 Trusted Roles, on which the security of the CA's operation is dependent, are clearly identified. Trusted
roles include, at a minimum, the following responsibilities:
a) overall responsibility for administering the implementation of the CA’s security practices;
b) approval of the generation, revocation and suspension of certificates;
c) installation, configuration and maintenance of the CA systems;
d) day-to-day operation of CA systems and system backup and recovery;
e) viewing and maintenance of CA system archives and audit logs;
f) cryptographic key life cycle management functions (e.g., key component custodians); and
g) CA systems development.
4 The CA’s policies and procedures specify the background checks and clearance procedures required for
Trusted Roles and non-trusted roles. As a minimum, verification checks on permanent staff are
performed at the time of job application and periodically for those individuals undertaking Trusted
Roles.

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5 An individual’s trusted status is approved prior to gaining access to systems/facilities or performing
actions requiring trusted status.
6 CA Employees and Trusted Roles sign a confidentiality (non-disclosure) agreement as a condition of
employment.
7 Contractors who perform Trusted Roles are subject to at least the same background check and personnel
management procedures as employees.
8 Any contract arrangement between Contractors and CAs allows for the provision of temporary contract
personnel that explicitly allows the organization to take measures against contract staff who violate the
organization’s security policies. Protective measures may include:
a) bonding requirements on contract personnel;
b) indemnification for damages due to contract personnel wilful harmful actions; and
c) financial penalties.
9 Periodic reviews occur to verify the continued trustworthiness of personnel involved in the activities
related to key management and certificate management.
10 A formal disciplinary process exists and is followed for employees who have violated organizational
security policies and procedures. The CA’s policies and procedures specify the sanctions against
personnel for unauthorized actions, unauthorized use of authority, and unauthorized use of systems.
11 Physical and logical access to CA facilities and systems is disabled upon termination of employment.
12 If required based on a risk assessment, duress alarms are provided for users who might be the target of
coercion.
13 All employees of the organization and, where relevant, third party contractors, receive appropriate
training in organizational policies and procedures. The CA’s policies and procedures specify the
following:
a) The training requirements and training procedures for each role; and
b) Any retraining period and retraining procedures for each role.

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3.4 Physical and Environmental Security
Criteria:
 physical access to CA facilities and equipment is limited to authorized individuals, protected through
restricted security perimeters, and is operated under multiple person (at least dual custody) control;
 CA facilities and equipment are protected from environmental hazards;
 loss, damage or compromise of assets and interruption to business activities are prevented; and
 compromise of information and information processing facilities is prevented.
CA Facility Physical Security
1 Entry to the building or site containing the CAs certificate manufacturing facility is achieved only
through a limited number of controlled access points.
2 All critical CA operations take place within a physically secure facility with at least four layers of
security to access sensitive hardware or software. Such systems are physically separated from the
organization’s other systems so that only authorized employees of the CA can access them.
3 A manned reception area or other means to control physical access is in place to restrict access to the
building or site housing CA operations to authorized personnel only.
4 Physical barriers are in place (e.g., solid walls that extend from real floor to real ceiling) to prevent
unauthorized entry and environmental contamination to the CAs certificate manufacturing facility.
5 Physical barriers are in place (e.g., Faraday cage) to prevent electromagnetic radiation emissions for all
Root CA operations (e.g., key generation and certification of CA Certificates) as disclosed in CP and/or
CPS.
6 Fire doors on security perimeters around CA operational facilities are alarmed and conform to local fire
regulations.
7 Intruder detection systems are installed and regularly tested to cover all external doors of the building
housing the CA operational facilities.
8 CA operational facilities are physically locked and alarmed when unoccupied.
9 All personnel are required to wear visible identification. Employees are encouraged to challenge anyone
not wearing visible identification.

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10 Access to CA operational facilities is controlled and restricted to authorized persons through the use of
multi-factor authentication controls.
11 All personnel entering and leaving CA operational facilities are logged (i.e., an audit trail of all access is
securely maintained).
12 Entry, exit, and activities within CA facilities are monitored by cameras.
13 Visitors to CA facilities are supervised and their date and time of entry and departure recorded.
14 Third party support services personnel is granted restricted access to secure CA operational facilities
only when required and such access is authorized and accompanied.
15 Access rights to CA facilities are regularly reviewed and updated.
Equipment Security
16 The CA maintains an equipment inventory.
17 Equipment is sited or protected such as to reduce the risks from environmental threats and hazards, and
opportunities for unauthorized access.
18 Equipment is protected from power failures and other electrical anomalies.
19 Power and telecommunications, within the facility housing the CA operation, cabling carrying data or
supporting CA services is protected from interception or damage.
20 Equipment is maintained in accordance with the manufacturer’s instructions and/or other documented
procedures.
21 All items of equipment containing storage media (fixed and removable disks) are checked to ensure that
they do not contain sensitive data prior to their disposal. Storage media containing sensitive data is
physically destroyed or securely overwritten prior to disposal or reused.
General Controls
22 Sensitive or critical business information is locked away when not required and when the CA facility
is vacated.
23 Procedures require that personal computers and workstations are logged off or protected by key locks,
passwords or other controls when not in use.
24 The movement of materials to/from the CA facility requires prior authorization.

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3.5 Operations Management
Criteria:
 the correct and secure operation of CA information processing facilities is ensured;
 the risk of CA systems failure is minimized;
 the integrity of CA systems and information is protected against viruses and malicious software;
 damage from security incidents and malfunctions is minimized through the use of incident reporting and
response procedures; and
 media are securely handled to protect them from damage, theft and unauthorized access.
Operational Procedures and Responsibilities
1 CA operating procedures are documented and maintained for each functional area.
2 Formal management responsibilities and procedures exist to control all changes to CA equipment,
software and operating procedures.
3 Duties and areas of responsibility are segregated in order to reduce opportunities for unauthorized
modification or misuse of information or services.
4 Development and testing facilities are separated from operational facilities.
5 Prior to using external facilities management services, risks and related controls are identified, agreed
upon with the contractor, and incorporated into the contract.
System Planning and Acceptance
6 Capacity demands are monitored and projections of future capacity requirements made to ensure that
adequate processing power and storage are available.
7 Acceptance criteria for new information systems, upgrades and new versions are established and
suitable tests of the system carried out prior to acceptance.
Protection Against Viruses and Malicious Software
8 Detection and prevention controls to protect against viruses and malicious software are implemented.
Employee awareness programs are in place.
Incident Reporting and Response
9 A formal security incident reporting procedure exists setting out the actions to be taken on receipt of
an incident report. This includes a definition and documentation of assigned responsibilities and
escalation procedures. Any incidents are reported to PA as a matter of urgency.

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10 Users of CA systems are required to note and report observed or suspected security weaknesses in, or
threats to, systems or services as they are detected.
11 Procedures exist and are followed for reporting hardware and software malfunctions.
12 Procedures exist and are followed to assess that corrective action is taken for reported incidents.
13 A formal problem management process exists that allows the types, volumes and impacts of incidents
and malfunctions to be documented, quantified and monitored.
Media Handling and Security
14 Procedures for the management of removable computer media require the following:
a) if no longer required, the previous contents of any reusable media that are to be removed from the
organization are erased or media is destroyed;
b) authorization is required for all media removed from the organization and a record of all such
removals to maintain an audit trail is kept; and
c) all media are stored in a safe, secure environment, in accordance with manufacturers’
specifications.
15 Equipment containing storage media (i.e., fixed hard disks) is checked to determine whether they
contain any sensitive data prior to disposal or reuse. Storage devices containing sensitive information
are physically destroyed or securely overwritten prior to disposal or reuse.
16 Procedures for the handling and storage of information exist and are followed in order to protect such
information from unauthorized disclosure or misuse.
17 System documentation is protected from unauthorized access.
3.6 System Access Management
Criteria:
The CA maintains controls to provide reasonable assurance that CA system access is limited to authorized
individuals. Such controls provide reasonable assurance that:
 operating system and database access is limited to authorized individuals with predetermined task
privileges;
 access to network segments housing CA systems is limited to authorized individuals, applications and
services; and
 CA application use is limited to authorized individuals.
User Access Management

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1 Business requirements for access control are defined and documented in an access control policy that
includes at least the following:
a) roles and corresponding access permissions;
b) identification and authentication process for each user;
c) segregation of duties; and
d) number of persons required to perform specific CA operations (i.e., m of n rule where m represents
the number of key shareholders required to perform an operation and n represents the total number
of key shares).
2 There is a formal user registration and de-registration procedure for access to CA information systems
and services.
3 The allocation and use of privileges is restricted and controlled.
4 The allocation of passwords is controlled through a formal management process.
5 Access rights for users with trusted roles are reviewed at regular intervals and updated.
6 Users are required to follow defined policies and procedures in the selection and use of passwords.
7 Users are required to ensure that unattended equipment has appropriate protection.
Network Access Control
8 CA employed personnel are provided direct access only to the services that they have been specifically
authorized to use. The path from the user terminal to computer services is controlled.
9 Remote access to CA systems, made by CA employees or external systems, if permitted, requires
authentication.
10 Connections made by CA employees or CA systems to remote computer systems are authenticated.
11 Access to diagnostic ports is securely controlled.
12 Controls (e.g., firewalls) are in place to protect the CA’s internal network domain from any
unauthorized access from any other domain.
13 Controls are in place to limit the network services (e.g., HTTP, FTP, etc.) available to authorized users
in accordance with the CA’s access control policies. The security attributes of all network services
used by the CA organization are documented by the CA.
14 Routing controls are in place to ensure that computer connections and information flows do not breach
the CA’s access control policy.

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15 The CA maintains local network components (e.g., firewalls and routers) in a physically secure
environment and audits their configurations periodically for compliance with the CA’s configuration
requirements.
16 Sensitive data is encrypted when exchanged over public or untrusted networks.
Operating System and Database Access Control
17 Operating systems and databases are configured in accordance with the CA’s system configuration
standards and periodically reviewed and updated.
18 Operating system and database patches and updates are applied in a timely manner when deemed
necessary based on a risk assessment.
19 Automatic terminal identification is used to authenticate connections to specific locations and to
portable equipment.
20 Access to CA systems requires a secure logon process.
21 All CA personnel users have a unique identifier (user ID) for their personal and sole use so that
activities can be traced to the responsible individual. Where shared or group accounts are required,
other monitoring controls are implemented to maintain individual accountability.
22 Uses of system utility programs are restricted to authorized personnel and tightly controlled.
23 Inactive terminals serving CA systems require re-authentication prior to use.
24 Restrictions on connection times are used to provide additional security for high-risk applications.
25 Sensitive data is protected against disclosure to unauthorized users.
Application Access Control
26 Access to information and application system functions is restricted in accordance with the CA’s
access control policy.
27 CA personnel are successfully identified and authenticated before using critical applications related to
certificate management.
28 Sensitive systems (e.g., Root CA) require a dedicated (isolated) computing environment.

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3.7 Systems Development and Maintenance
Criteria:
The CA maintains controls to provide reasonable assurance that CA systems development and maintenance
activities are documented, tested, authorized, and properly implemented to maintain CA system integrity.
1 Business requirements for new systems, or enhancements to existing systems specify the control
requirements.
2 Software testing and change control procedures exist and are followed for the implementation of
software on operational systems including scheduled software releases, modifications and emergency
software fixes.
3 Change control procedures exist and are followed for the hardware, network component, and system
configuration changes.
4 Test data is protected and controlled.
5 Control is maintained over access to program source libraries.
6 Application systems are reviewed and tested when operating system changes occur.
7 The implementation of changes is strictly controlled by the use of formal change control procedures to
minimize the risk of corruption of information systems.
8 Modifications to software packages are discouraged and all changes are strictly controlled.
9 The purchase, use and modification of software are controlled and checked to protect against possible
covert channels and Trojan code. This includes the authentication of the source of the software. These
controls apply equally to outsourced software development.

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3.8 Business Continuity Management
Criteria:
The CA maintains controls to provide reasonable assurance of continuity of operations in the event of a
disaster. Such controls include, at a minimum:
 the development and testing of a CA business continuity plan that includes a disaster recovery process for
critical components of the CA system;
 the storage of required cryptographic materials (i.e., secure cryptographic device and activation materials)
at an alternate location;
 the storage of backups of systems, data and configuration information at an alternate location; and
 the availability of an alternate site, equipment and connectivity to enable recovery.
The CA maintains controls to provide reasonable assurance that potential disruptions to Subscribers and
Relying Parties are minimized as a result of the cessation or degradation of the CA’s services.
1 The CA has a managed process for developing and maintaining its business continuity plans. The CA
has a business continuity planning strategy based on an appropriate risk assessment.
2 The CA has a business continuity plan to maintain or restore the CA’s operations in a timely manner
following interruption to, or failure of, critical CA processes. The CA’s business continuity plan
addresses the following:
a) the conditions for activating the plans;
b) emergency procedures;
c) fallback procedures;
d) resumption procedures;
e) a maintenance schedule for the plan;
f) awareness and education requirements;
g) the responsibilities of the individuals;
h) recovery time objective (RTO); and
i) regular testing of contingency plans.
3 The CA’s business continuity plans include disaster recovery processes for all critical components of a
CA system, including the hardware, software and keys, in the event of a failure of one or more of these
components. Specifically:
a) cryptographic devices used for storage of backup CA private keys are securely stored at an off-site
location in order for the CA to recover in the event of a disaster at the primary CA facility; and
b) the requisite secret key shares or key components, needed to use and manage the disaster recovery
cryptographic devices, are securely stored at an off-site location.

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4 Backup copies of essential business information are regularly taken. The security requirements of these
copies are consistent with the controls for the information backed up.
5 The CA identifies and arranges for an alternate site where core PKI operations can be restored in the
event of a disaster at the CA’s primary site. Fallback equipment and backup media are sited at a safe
distance to avoid damage from disaster at the main site.
6 The CA’s business continuity plans include procedures for securing its facility to the extent possible
during the period of time following a disaster and prior to restoring a secure environment either at the
original or a remote site.
7 The CA’s business continuity plans address the recovery procedures used if computing resources,
software, and/or data are corrupted or suspected to be corrupted.
8 Business continuity plans are tested regularly to ensure that they are up to date and effective.
9 Business continuity plans define an acceptable system outage time, recovery time, and the average time
between failures as disclosed in the CP and/or CPS.
10 Business continuity plans are maintained by regular reviews and updates to ensure their continuing
effectiveness.
11 The CA maintains procedures for the termination, notification of affected entities, and for transferring
relevant archived CA records to a custodian as disclosed in the CP and/or CPS.

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3.9 Monitoring and Compliance
Criteria:
 it conforms with the relevant legal, regulatory and contractual requirements;
 compliance with the CA’s security policies and procedures is ensured;
 the effectiveness of the system audit process is maximized and interference to and from the system audit
process is minimized; and
 unauthorized CA system usage is detected.
Compliance with Legal Requirements
1 Relevant statutory, regulatory and contractual requirements are explicitly defined and documented.
2 The CA has implemented procedures to comply with legal restrictions on the use of material in respect
of intellectual property rights, and on the use of proprietary software products.
3 Controls are in place to ensure compliance with national agreements, laws, regulations or other
instruments to control the access to or use of cryptographic hardware and software.
4 Procedures exist to ensure that personal information is protected in accordance with relevant legislation.
5 The information security policy addresses the following:
a) the information that must be kept confidential by CA or RA;
b) the information that is not considered confidential;
c) the policy on release of information to law enforcement officials;
d) information that can be revealed as part of civil discovery;
e) the conditions upon which information may be disclosed with the subscriber’s consent; and
f) any other circumstances under which confidential information may be disclosed.
6 CA records are protected from loss, unauthorized destruction and falsification.
7 Management authorizes the use of information processing facilities and controls are applied to prevent
the misuse of such facilities.
Review of Security Policy and Technical Compliance
8 Managers are responsible for ensuring that security procedures within their area of responsibility are
carried out correctly.
9 The CA’s operations are subject to regular review to ensure timely compliance with its CPS.

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10 CA systems are periodically checked for compliance with security implementation standards.
System Audit Process
11 Audits of operational systems are planned and agreed such as to minimize the risk of disruptions to
business processes.
12 Access to system audit tools is protected to prevent possible misuse or compromise.
Monitoring System Access and Use
13 Procedures for monitoring the use of CA systems are established which include the timely identification
and follow up of unauthorized or suspicious activity. Alerting mechanisms are implemented to detect
unauthorized access.
3.10 Audit Logging
Criteria:
 significant CA environmental, key management, and certificate management events are accurately and
appropriately logged;
 the confidentiality and integrity of current and archived audit logs are maintained;
 audit logs are completely and confidentially archived in accordance with disclosed business practices; and
 audit logs are reviewed periodically by authorized personnel.
Audit Logs
1 The CA generates automatic (electronic) and manual audit logs in accordance with the requirements
of the CP and/or CPS.
2 All journal entries include the following elements:
a) date and time of the entry;
b) serial or sequence number of entry (for automatic journal entries);
c) kind of entry;
d) source of entry (e.g., terminal, port, location, customer, etc.); and
e) identity of the entity making the journal entry.

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Events Logged
3 The CA logs the following CA and subscriber (if applicable) key life cycle management related events:
a) CA key generation;
b) installation of manual cryptographic keys and its outcome (with the identity of the operator);
c) CA key backup;
d) CA key storage;
e) CA key recovery;
f) CA key escrow activities (if applicable);
g) CA key usage;
h) CA key archival;
i) withdrawal of keying material from service;
j) CA key destruction;
k) identity of the entity authorizing a key management operation;
l) identity of the entities handling any keying material (such as key components or keys stored in
portable devices or media);
m) custody of keys and of devices or media holding keys; and
n) compromise of a private key.
4 The CA logs the following cryptographic device life cycle management related events:
a) device receipt and installation;
b) placing into or removing a device from storage;
c) device activation and usage;
d) device de-installation;
e) designation of a device for service and repair; and
f) device retirement.
5 If the CA provides subscriber key management services, the CA logs the following subscriber key life
cycle management related events:
a) key generation;
b) key distribution (if applicable);
c) key backup (if applicable);
d) key escrow (if applicable);
e) key storage;
f) key recovery (if applicable);
g) key archival (if applicable);
h) key destruction;
i) identity of the entity authorizing a key management operation; and
j) key compromise.

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6 The CA records (or requires that the RA record) the following certificate application information:
a) the method of identification applied and information used to meet subscriber requirements;
b) record of unique identification data, numbers, or a combination thereof (e.g., applicants drivers
license number) of identification documents, if applicable;
c) storage location of copies of applications and identification documents;
d) identity of entity accepting the application;
e) method used to validate identification documents, if any;
f) name of receiving CA or submitting RA, if applicable;
g) the subscriber’s acceptance of the Subscriber Agreement; and
h) where required under privacy legislation, the Subscriber’s consent to allow the CA to keep records
containing personal data, pass this information to specified third parties, and publication of
certificates.
7 The CA logs the following certificate life cycle management related events:
a) receipt of requests for certificate(s) – including initial certificate requests, renewal requests and
rekey requests;
b) submissions of public keys for certification;
c) change of affiliation of an entity;
d) generation of certificates;
e) distribution of the CA’s public key;
f) certificate revocation requests;
g) certificate revocation;
h) certificate suspension requests (if applicable);
i) certificate suspension and reactivation; and
j) generation and issuance of Certificate Revocation Lists.
8 The CA logs the following security-sensitive events:
a) security-sensitive files or records read or written including the audit log itself;
b) actions taken against security-sensitive data;
c) security profile changes;
d) use of identification and authentication mechanisms, both successful and unsuccessful (including
multiple failed authentication attempts);
e) system crashes, hardware failures and other anomalies;
f) actions taken by individuals in Trusted Roles, computer operators, system administrators, and
system security officers;
g) change of affiliation of an entity;
h) decisions to bypass encryption/authentication processes or procedures; and
i) access to the CA system or any component thereof.
9 Audit logs do not record the private keys in any form (e.g., plaintext or enciphered).
10 CA computer system clocks are synchronized for accurate recording as defined in the CP and/or CPS
that specifies the accepted time source.

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Audit Log Protection
11 Current and archived audit logs are maintained in a form that prevents their modification, substitution,
or unauthorized destruction.
12 Digital signatures are used to protect the integrity of audit logs where applicable or required to satisfy
legal requirements.
13 The private key used for signing audit logs is not used for any other purpose. This applies equally to a
symmetric secret key used with a symmetric MAC mechanism.
Audit Log Archival
14 The CA archives audit log data on a periodic basis as disclosed in the CP and/or CPS.
15 In addition to possible regulatory stipulation, a risk assessment is performed to determine the
appropriate length of time for retention of archived audit logs.
16 The CA maintains archived audit logs at a secure off-site location for a predetermined period as
determined by risk assessment and legal requirements.
Review of Audit Logs
17 Current and archived audit logs are only retrieved by authorized individuals for valid business or
security reasons.
18 Audit logs are reviewed periodically according to the practices established in the CPS. The review of
current and archived audit logs include a validation of the audit logs’ integrity, and the timely
identification and follow up of unauthorized or suspicious activity.

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4. CA KEY LIFE CYCLE MANAGEMENT CONTROLS
The Certification Authority maintains effective controls to provide reasonable assurance that the integrity
of keys and certificates it manages is established and protected throughout their life cycles.
4.1 CA Key Generation
Criteria:
The CA maintains controls to provide reasonable assurance that CA key pairs are generated in accordance
with the CA’s disclosed business practices and defined procedures specified within detailed key generation
ceremony scripts.
The CA’s disclosed business practices include but are not limited to:
a) generation of CA keys are undertaken in a physically secured environment (see §3.4);
b) generation of CA keys are performed by personnel in trusted roles (see §3.3) under the principles of
multiple person control and split knowledge;
c) generation of CA keys occur within cryptographic modules meeting the applicable technical and business
requirements as disclosed in the CA’s CPS;
d) generation of CA keys are witnessed by an independent party and/or videotaped; and
e) CA key generation activities are logged.
The CA key generation script includes the following:
a) definition of roles and participant responsibilities;
b) approval for conduct of the key generation ceremony;
c) cryptographic hardware and activation materials required for the ceremony;
d) specific steps performed during the key generation ceremony;
e) physical security requirements for the ceremony location;
f) procedures for secure storage of cryptographic hardware and activation materials following the key
generation ceremony;
g) sign-off from participants and witnesses indicating whether key generation ceremony was performed in
accordance with the detailed key generation ceremony script; and
h) notation of any deviations from the key generation ceremony script.

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Generation of CA Keys Including Root CA Keys – General Requirements
1 Generation of CA keys occur within a cryptographic module meeting the applicable requirements of
ISO 15782-1/FIPS 140-2 (or equivalent)/ANSI X9.66 and the business requirements in accordance with
the CPS. Such cryptographic devices perform key generation using a random number generator (RNG)
or pseudo random number generator (PRNG).
2 The CA generates its own key pair in the same cryptographic device in which it will be used or the key
pair is injected directly from the device where it was generated into the device where it will be used.
3 CA key generation generates keys which:
a) use a key generation algorithm as disclosed within the CA’s CP and/or CPS;
b) have a key length that is appropriate for the algorithm and for the validity period of the CA
certificate as disclosed in the CA’s CP and/or CPS. The public key length to be certified by a CA is
less than or equal to that of the CA’s private signing key; and
c) take into account requirements on parent and subordinate CA key sizes and have a key size in
accordance with the CA’s CP and/or CPS.
4 CA key generation ceremonies are independently witnessed by internal or external auditors.
Generation of CA Keys Including Root CA Keys – Script Requirements
5 The CA follows a CA key generation script for key generation ceremonies that includes the following:
a) definition and assignment of participant roles and responsibilities;
b) management approval for conduct of the key generation ceremony;
c) specific cryptographic hardware, software and other materials including identifying information,
e.g., serial numbers;
d) specific steps performed during the key generation ceremony;
 Hardware preparation;
 Operating system installation;
 CA application installation and configuration;
 CA key generation;
 CA key backup;
 CA certificate signing;
 CA system shutdown; and
 Preparation of materials for storage.
e) physical security requirements for the ceremony location (e.g., barriers, access controls and logging
controls);
f) procedures for secure storage of cryptographic hardware and activation materials following the key
generation ceremony (e.g., detailing the allocation of materials between storage locations);
g) sign-off on the script or in a log from participants and witnesses indicating whether key generation
ceremony was performed in accordance with the detailed key generation ceremony script; and
h) notation of any deviations from the key generation ceremony script (e.g., documentation of steps
taken to address any technical issues).

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6 The integrity of the hardware/software used for key generation and the interfaces to the
hardware/software is tested before production usage.
4.2 CA Key Storage, Backup and Recovery
Criteria:
The CA maintains controls to provide reasonable assurance that CA private keys remain confidential and
maintain their integrity. The CA’s private keys are backed up, stored and recovered by authorized personnel in
trusted roles, using multiple person control in a physically secured environment.
1 The CA’s private (signing and confidentiality) keys are stored and used within a secure cryptographic
device meeting the appropriate ISO 15408 protection profile or FIPS 140-2 level requirement based on
a risk assessment and the business requirements of the CA and in accordance with the CA’s CPS and
applicable Certificate Policy(s).
2 If the CA’s private keys are not exported from a secure cryptographic module, then the CA private key
is generated, stored and used within the same cryptographic module.
3 If the CA’s private keys are exported from a secure cryptographic module to secure storage for
purposes of offline processing or backup and recovery, then they are exported within a secure key
management scheme that may include any of the following:
a) as cipher-text using a key which is appropriately secured;
b) as encrypted key fragments using multiple control and split knowledge/ownership; or
c) in another secure cryptographic module such as a key transportation device using multiple control.
4 Backup copies of the CA’s private keys are subject to the same or greater level of security controls as
keys currently in use. The recovery of the CA’s keys is carried out in as secure a manner as the backup
process, using multi-person control.
4.3 CA Public Key Distribution
Criteria:
The CA maintains controls to provide reasonable assurance that the integrity and authenticity of the CA public
keys and any associated parameters are maintained during initial and subsequent distribution.

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1 For the Root CA distribution process (e.g., using a self-signed certificate), an out-of-band notification
mechanism is employed. Where a self-signed certificate is used for any CA, the CA provides a
mechanism to verify the authenticity of the self-signed certificate (e.g., publication of the certificate’s
fingerprint).
For subsequent and/or Subordinate CA public keys these are validated by using a chaining method or
similar process to link back to the trusted Root Certificate.
2 The initial distribution mechanism for the CA’s public key is controlled and initially distributed within a
Certificate using one of the following methods:
a) machine readable media (e.g., smart card, CD ROM) from an authenticated source;
b) embedding in an entity’s cryptographic module; or
c) other secure means that ensure authenticity and integrity.
3 The CA’s public key is changed (rekeyed) periodically according to the requirements of the CPS with
advance notice provided to avoid disruption of the CA services.
4 The subsequent distribution mechanism for the CA’s public key is controlled in accordance with the
CA’s disclosed business practices.
5 If an entity already has an authenticated copy of the CA’s public key, a new CA public key is
distributed using one of the following methods:
a) direct electronic transmission from the CA;
b) placing into a remote cache or directory;
c) loading into a cryptographic module; or
d) any of the methods used for initial distribution.
6 The CA provides a mechanism for validating the authenticity and integrity of the CA’s public keys.
4.4 CA Key Usage
Criteria:
The CA maintains controls to provide reasonable assurance that CA keys are used only for their intended
functions in their predetermined locations.
1 The activation of the CA private signing key is performed using multi-party control (i.e., m of n) with
a minimum value of m (e.g., m greater than 2 for Root CAs).

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2 If necessary based on a risk assessment, the activation of the CA private key is performed using multi-
factor authentication (e.g., smart card and password, biometric and password, etc.).
3 CA signing key(s) used for generating certificates and/or issuing revocation status information, are not
used for any other purpose.
4 The CA ceases to use a key pair at the end of the key pair’s defined operational lifetime or when the
compromise of the private key is known or suspected.
5 An annual review is required by the PA on key lengths to determine the appropriate key usage period
with recommendations acted upon.
4.5 CA Key Archival and Destruction
Criteria:
 archived CA keys remain confidential and secured and are never put back into production; and
 CA keys are completely destroyed at the end of the key pair life cycle in accordance with the CA’s
disclosed business practices.
CA Key Archival
1 Archived CA keys are subject to the same or greater level of security controls as keys currently in use.
2 All archived CA keys are destroyed at the end of the archive period using dual control in a physically
secure site.
3 Archived keys are only accessed where historical evidence requires validation. Control processes are
required to ensure the integrity of the CA systems and the key sets.
4 Archived keys are recovered for the shortest possible time period technically permissible to meet
business requirements.

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5 Archived keys are periodically verified to ensure that they are properly destroyed at the end of the
archive period.
CA Key Destruction
6 The CA’s private keys are not destroyed until the business purpose or application has ceased to have
value or legal obligations have expired as disclosed within the CA’s CPS.
7 Authorization to destroy a CA private key and how the CA’s private key is destroyed (e.g., token
surrender, token destruction, or key overwrite) are limited in accordance with the CA’s CPS.
8 All copies and fragments of the CA’s private key are destroyed at the end of the key pair life cycle in a
manner such that the private key cannot be retrieved.
9 If a secure cryptographic device is accessible and known to be permanently removed from service, all
CA private keys stored within the device that have ever been or potentially could be used for any
cryptographic purpose are destroyed.
10 If a CA cryptographic device is being permanently removed from service, then any key contained
within the device that has been used for any cryptographic purpose is erased from the device.
11 If a CA cryptographic device case is intended to provide tamper-evident characteristics and the device
is being permanently removed from service, then the case is destroyed.
4.6 CA Key Compromise
Criteria:
The CA maintains controls to provide reasonable assurance that continuity of operations is maintained in the
event of the compromise of the CA’s private keys and any certificates, signed with the compromised keys, are
revoked and reissued.
1 The CA’s business continuity plans address the compromise or suspected compromise of a CA’s
private keys as a disaster.
2 Disaster recovery procedures include the revocation and reissuance of all certificates that were signed
with that CA’s private key, in the event of the compromise or suspected compromise of a CA’s private
signing key.

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3 The recovery procedures used if the CA’s private key is compromised include the following actions:
a) how secure key usage in the environment is re-established;
b) how the CA’s old public key is revoked;
c) how affected parties are notified (e.g., impacted CAs, Repositories, Subscribers and CVSPs);
d) how the CA’s new public key is provided to the end entities and Relying Parties together with the
mechanism for their authentication; and
e) how the subscriber’s public keys are re-certified.
4 In the event that the CA has to replace its Root CA private key, procedures are in place for the secure
and authenticated revocation of the following:
a) the old CA root public key;
b) the set of all certificates (including any self-signed) issued by a Root CA or any CA based on the
compromised private key; and
c) any subordinate CA public keys and corresponding certificates that require recertification.
5 The CA’s business continuity plan for key compromise addresses who is notified and what actions are
taken with system software and hardware, symmetric and asymmetric keys, previously generated
signatures and encrypted data.
4.7 CA Cryptographic Hardware Life Cycle Management
Criteria:
 devices used for private key storage and recovery and the interfaces to these devices are tested before
usage for integrity;
 access to CA cryptographic hardware is limited to authorized personnel in trusted roles, using multiple
person control; and
 CA cryptographic hardware is functioning correctly.
1 CA cryptographic hardware is sent from the manufacturer via registered mail (or equivalent) using tamper
evident packaging. Upon the receipt of CA cryptographic hardware from the manufacturer, authorized CA
personnel inspects the tamper evident packaging to determine whether the seal is intact.
2 Upon the receipt of CA cryptographic hardware from the manufacturer, acceptance testing and
verification of firmware settings is performed. Upon the receipt of CA cryptographic hardware that
has been serviced or repaired, acceptance testing and verification of firmware settings is performed.

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3 To prevent tampering, CA cryptographic hardware is stored and used in a secure site, with access
limited to authorized personnel, having the following characteristics:
a) inventory control processes and procedures to manage the origination, arrival, condition, departure
and destination of each device;
b) access control processes and procedures to limit physical access to authorized personnel;
c) recording of all successful or failed access attempts to the CA facility and device storage
mechanism (e.g., a safe) in audit logs;
d) incident handling processes and procedures to handle abnormal events, security breaches, and
investigation and reports; and
e) monitoring processes and procedures to verify the ongoing effectiveness of the controls.
4 When not attached to the CA system, the CA cryptographic hardware is stored in a tamper resistant
container that is stored securely under multiple controls (i.e., a safe).
5 The handling of CA cryptographic hardware, including the following tasks, is performed in the
presence of no less than two trusted employees:
a) installation of CA cryptographic hardware;
b) removal of CA cryptographic hardware from production;
c) servicing or repair of CA cryptographic hardware (including installation of new hardware,
firmware, or software); and
d) disassembly and permanent removal from use.
6 Devices used for private key storage and recovery and the interfaces to these devices are tested before
usage for integrity.
7 Correct processing of CA cryptographic hardware is verified on a periodic basis.
8 Diagnostic support is provided during troubleshooting of CA cryptographic hardware in the presence
of no less than two trusted employees.
4.8 CA Key Escrow (if applicable)
Criteria:
The CA maintains controls to provide reasonable assurance that escrowed CA private signing keys remain
confidential.
1 If a third party provides CA private key escrow services, a contract exists that outlines the liabilities
and remedies between the parties.

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2 If CA private signing keys are held in escrow, escrowed copies of the CA private signing keys have
the same or greater level of security controls as keys currently in use.

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