Ballot SMC06: Post implementation clarification and corrections

Ballot overview

• Ballot SMC06, Post implementation clarification and corrections, updated the S/MIME Baseline Requirements to version 1.0.4.
• The ballot was adopted and the voting period completed with the ballot passed.
• The IPR Review Period completed with no IPR Exclusion Notices filed.

What changed

• Added a new requirement to check the Active status of Legal Entity Applicants.
• Clarified and corrected several S/MIME Baseline Requirements sections, including:
  • Mailbox-validated certificates may include subject:commonName.
  • Sponsor-validated certificates may be registered by an Enterprise RA.
  • Extant S/MIME CA definition now refers to inclusion in a valid trust chain of an end entity S/MIME Certificate.
  • Organization identity verification now includes checking that applicant status is not labeled as ceased, inactive, invalid, not current, or equivalent in certain cases.
  • Suspension handling now limits use to certificateHold and applies to Subscriber Certificates.
  • Private key transport and encryption requirements were revised.
  • Several subject field and registration identifier clarifications were made.

Compliance timing

• The revised S/MIME BR v.1.0.4 was published as of May 11, 2024.
• The ballot’s additional compliance date for the requirement to check Active status of Legal Entity Applicants is September 15, 2024.
• The ballot text also states that these requirements apply only to relevant events that occur on or after the relevant Effective Date described in the requirements.

Voting and IPR

• Start of Review Period: April 11, 2024
• End of Review Period: 2359 UTC on May 11, 2024
• The ballot passed with 16 Certificate Issuer yes votes and 3 Certificate Consumer yes votes.
• Bylaw quorum and voting thresholds were met for both Certificate Issuers and Certificate Consumers.