Ballot 174 – Reform of Requirements Relating to Conflict with Local Laws

Ballot overview

• Ballot 174, Reform of Requirements Relating to Conflict with Local Laws, was a Server Certificate Working Group ballot.
• The ballot passed with 21 YES, 0 NO, and 1 abstention from CAs, and 3 YES, 0 NO, and 0 abstentions from browsers.
• The page states that voting on the ballot has now closed and that the ballot passes.

What changed

• The motion deletes Baseline Requirements section 9.16.3, Severability, and replaces it with a new rule for conflicts between the Requirements and a law, regulation, or government order.
• Under the new text, a CA may modify a conflicting requirement only to the minimum extent necessary to make it valid and legal in the jurisdiction.
• The change applies only to operations or certificate issuances subject to that law.
• Before issuing a certificate under the modified requirement, the CA must:
  • add a detailed reference to the law and the specific modification in section 9.16.3 of its CPS
  • notify the CA/Browser Forum by sending a message to the Public Mailing List and receiving confirmation that it was posted and indexed in the Public Mail Archives
• Any such modification to CA practice must be discontinued if the law no longer applies or if the Requirements are changed so both can be complied with simultaneously.
• An appropriate change in practice, CPS update, and notice to the CA/Browser Forum must be made within 90 days.

Compliance timing

• The ballot states that CAs are required to make this change to their processes by a date 90 days from the date this ballot passes.
• The review period was to close at 2200 UTC on Monday 22nd August, and the voting period was to close at 2200 UTC on Monday 29th August.

Result

• The ballot passed.
• The evidence does not provide a calendar date for the 90-day compliance deadline, only that it is 90 days from the date the ballot passes.