ETSI EN 319 411-1 CA Key Management

The certificate policy (CP) states the rules for the certificate service; the Certification Practice Statement (CPS) describes how the provider follows them. ETSI EN 319 411-1 requires the CPS to include the signature algorithms and parameters used by the TSP, and to specify the practice for using CA keys to sign certificates, CRLs, and OCSP. Treat those CPS clauses as the control baseline for the key-management file.

A useful CA key-management record should identify every CA signing key, whether it is for a root or subordinate CA, how it is authorized for certificate issuance or revocation-status signing, and which CP/CPS text limits its use. Keep internal ceremony procedures private when necessary, but make sure the CPS and retained evidence still prove the public commitment.

Clause 6.5.1 requires a documented procedure for CA key pair generation for all CAs, including root CAs and subordinate CAs that issue end-user certificates. The ceremony file should show that the procedure was followed and that the integrity and confidentiality of the generated key pair were protected.

The standard is specific about ceremony evidence. The report should identify participating roles, functions performed in each phase, responsibilities during and after the ceremony, evidence collected, the ceremony date, generated-key inventory, secure cryptographic device details, and the configured generation algorithm and settings.

EN 319 411-1 expects TSP key pair generation, including keys used by revocation and registration services, to be carried out in a secure cryptographic device that meets the standard's assurance options. The CA private signing key must be held and used within that device, and any protection outside the device has to provide the same level of protection.

An HSM label is not enough. The record should identify which assurance route is used, prove the device was operated in its certified guidance configuration or an equivalent configuration that achieves the same security objective, document shipment and storage tamper controls, and show that access controls prevent key extraction. The ISO/IEC 15408 route permits equivalent recognized criteria only where the security target or protection profile meets this standard, based on risk analysis and relevant physical and non-technical measures.

Backup and recovery are part of the CA key-management surface, not a separate IT housekeeping task. EN 319 411-1 requires CA private signing-key backup, storage, and recovery to be performed only by personnel in trusted roles, using at least dual control in a physically secured environment, and with the number of authorized personnel kept to a minimum.

The same file should prove that the key was used only for its authorized lifecycle and purpose. EN 319 411-1 says CA signing keys used for certificate generation or revocation-status information are not to be used for any other purpose, are not to be used beyond lifecycle end, and copies are destroyed at lifecycle end. The business continuity or disaster recovery plan must treat compromise, loss, or suspected compromise of a CA private key as a disaster. In the case of compromise, the standard also requires notification and CA-certificate revocation actions.

Treat this checklist as an audit-file review before a key ceremony, CA changeover, conformity assessment, or major CPS update. Each item should be answered with a document, log, ceremony report, device record, or exception note rather than a generic statement of intent.