DigiCert: Apple: Non-compliant Common Name Length

DigiCert reported a compliance issue regarding the issuance of certificates with Common Names exceeding the 64-character limit as specified in the CA/Browser Forum Baseline Requirements. The issue was discovered on May 15, 2019, during a code review by an internal developer, who subsequently revoked two impacted certificates. The compliance team was notified on May 21, 2019, and a software fix was deployed on May 22, 2019, to enforce the character limit. A total of 28 certificates were identified as affected, issued between November 28, 2014, and March 25, 2019. DigiCert has since completed a gap analysis to ensure compliance with RFC 5280 and the Baseline Requirements, concluding that all requirements are now addressed.

1. 2019-05-15 Code review identified that the software was not enforcing a max length of 64 characters for Common Names.
2. 2019-05-22 Software fix deployed to enforce the character limit.
3. 2019-12-14 Gap analysis completed, confirming compliance with RFC 5280 and Baseline Requirements.

1. 2019-06-05 Apple representative — Created attachment with impacted certificates and incident report.
2. 2019-06-10 Apple representative — Responded to questions regarding compliance checks and improvements.
3. 2019-06-26 Apple representative — Provided additional context on the revocation process and compliance team notifications.
4. 2019-12-14 Apple representative — Announced completion of the gap assessment.