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Across 8 modules • Updated May 9, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Subscriber agreements under ETSI EN 319 411-1

What evidence should a CA retain for subscriber agreements?

The evidence should prove the exact agreement, the terms accepted, the person or entity accepting, and the specific choices made during registration. ETSI EN 319 411-1 requires the agreement with the subscriber to be recorded, and, where the subscriber and subject are separate, the subject agreement to be recorded as well.

Records should also connect the agreement to the registration file. ETSI EN 319 411-1 lists the storage location of applications and identification documents, including the subscriber agreement, plus specific choices in the agreement such as consent to certificate publication.

  • Retain the signed or electronically accepted subscriber agreement and the version of terms and conditions presented at acceptance.
  • Keep evidence of the wilful act used for acceptance, such as signature data, acceptance timestamp, account identity, or equivalent trace record.
  • Record publication consent, secure-cryptographic-device acceptance, certificate-information confirmation, and any other agreement choices that affect issuance or relying-party information.
  • Retain the agreement records for the period indicated to the subscriber as part of the terms and conditions.
Citations
Subscriber identity validation under ETSI EN 319 411-1

What must be validated before a certificate is issued?

Clause 6.2.2 starts with a direct rule: the TSP verifies the identity of the subscriber and the subject. It then requires the TSP to collect and validate either direct evidence or an attestation from an appropriate and authorized source for the subject's identity and, where applicable, subject attributes.

The validation decision must also cover the certificate request itself. ETSI EN 319 411-1 requires the TSP to check that certificate requests are accurate, authorized, and complete against the collected evidence or attestation. Identity verification happens at registration, and the registration service passes verified identity and attribute results to certificate generation.

  • Identify whether the subject is a natural person, a natural person linked to a legal person, a legal person or organizational entity, or a device or system operated by or for a natural or legal person.
  • Collect direct evidence or an authorized-source attestation for the subject identity and any certificate attributes that will be included or relied on.
  • Check request accuracy, authorization, and completeness before certificate generation uses the registration result.
Citations
Subscriber identity validation under ETSI EN 319 411-1

How does the answer change by subject type?

For natural-person subjects under NCP requirements, ETSI EN 319 411-1 expects identity evidence to be checked against the person directly by physical presence, unless a duly mandated subscriber represents the subject, or indirectly using means that provide equivalent assurance. The evidence set includes the person's full name and either date and place of birth, a recognized identity-document reference, or other distinguishing attributes.

For a natural person associated with a legal person, the file needs both personal and organization evidence: the subject's name and distinguishing attributes, the legal person's full name and legal status, relevant registration information, the affiliation, and approval by both the legal person and natural person that the subject attributes identify the organization. For legal-person and device/system subjects, the evidence shifts to the organization's name, registration or distinguishing attributes, relevant organizational associations, and a device identifier such as an Internet domain name where applicable.

  • Do not use a single identity checklist for every certificate profile; map the requested certificate to the subject type and policy conditions that apply.
  • When the subscriber and subject are different entities, keep evidence that the subscriber is authorized to act for the subject and, if the subscriber is not a natural person, that a natural person is authorized to represent the subscriber.
  • For web certificates, use the domain-name and IP-address verification methods in BRG clauses 3.2.2.4 to 3.2.2.9 for the applicable certificate profile, instead of a generic verification path.
Citations
Regulation (EU) No 910/2014 (eIDAS)

Provides the EU trust-services legal context for certificates and trust service providers where ETSI EN 319 411-1 is used for eIDAS-oriented certification services.

Subscriber identity validation under ETSI EN 319 411-1

What evidence should a CA keep for subscriber identity validation?

The evidence record should be specific enough to re-perform the validation decision without collecting unnecessary long-term personal data. ETSI EN 319 411-1 requires the TSP to record all information necessary to verify the subject identity and attributes, including any reference number on verification documentation and any limits on its validity. The standard notes that long-term retention may be limited to a reference to the document used, depending on the records obligations and applicable law.

The file should also prove process integrity. Keep the request, evidence or attestation source, validation method, certificate profile, subscriber contact attributes, authorization evidence, approval history, and the registration officer or RA record. The registration officer who verifies identity must not be the natural person receiving the certificate as subject.

  • Record the subject type, subscriber-subject relationship, certificate profile, evidence source, validation method, document reference, validity limitations, and request approval.
  • Keep subscriber contact attributes such as a physical address or other contact attributes, plus evidence showing how the registration process meets applicable data-protection legislation.
  • Track registration officer independence, RA involvement, and any delegated evidence source so the CA can show who validated what and under which CPS process.
Citations
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