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FAQGLOBALETSI EN 319 411-1

ETSI EN 319 411-1 Certificate re-key FAQ

A focused answer for TSP, CA, RA, and audit teams handling certificate re-key under ETSI EN 319 411-1.

Based on ETSI EN 319 411-1 V1.5.1 and the related ETSI EN 319 401 general TSP requirements.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
3

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2

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Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

Under ETSI EN 319 411-1 V1.5.1 (April 2025), means issuing a new certificate for an already issued subject with a new subject public key. keeps the previously certified public key. A re-keyed certificate may also update subject attributes or the expiry date when the CP/CPS allows it. Re-key does not revoke the earlier certificate, so the TSP must make a separate status decision for any unexpired certificate. EN 319 411-1 supplies a technical baseline; the applicable certificate policy, assessment scheme, contract, browser program, or law can add stricter validation, lifetime, or revocation rules.

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3 of 3 questions
Question 1

How should certificate authorities handle re-key under ETSI EN 319 411-1?

Treat re-key as a certificate lifecycle event that starts with a new subject public key. A instead keeps the previously certified public key and is allowed only when that key remains cryptographically sufficient for the new validity period and there is no indication of compromise or revocation for another security breach. ETSI EN 319 411-1 clause 6.3.7 says the general certificate application and application-processing requirements in clauses 6.3.1 and 6.3.2 still apply to re-key. The request must remain linked to registration, authorization, current identity or attribute evidence, and the public key being certified. If the CA did not generate the new key pair, the request process must provide reasonable assurance that the subject possesses or controls the corresponding private key.

The CP/CPS should be the operating boundary. It needs to state whether, and under which circumstances, the TSP allows to change the expiry date or certified attributes. If the previous certificate is used to authenticate the re-key request, the TSP checks that the previous certificate exists and is valid.

  • Confirm the event is re-key, not renewal: the subject public key changes.
  • Apply the certificate application and processing controls from clauses 6.3.1 and 6.3.2 to the re-key request.
  • Verify and record changed certified names or attributes before including them in the replacement certificate.
  • Check the existing certificate when it is used to authenticate the request.
  • Communicate and obtain agreement to changed terms and conditions before completing the re-key.
  • Decide separately whether an unexpired earlier certificate remains valid or must be revoked; issuing the re-keyed certificate does not automatically change the earlier certificate's status.
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Question 2

What evidence should support certificate re-key?

The evidence should prove why the re-key was allowed and how the new certificate was bound to the right subject. At minimum, keep the re-key request, request authentication result, registration or attribute evidence reused or refreshed, subscriber authorization where the subscriber and subject differ, and the CP/CPS rule that permits any expiry-date or attribute change.

ETSI EN 319 411-1 makes logging specific: registration events include requests for or renewal. Apply retention by record class. Clause 6.4.6 sets at least seven years after the relevant certificate ceases to be valid for CA-managed key-lifecycle logs and the clause 6.3.4 documentation it lists; other re-key records follow the applicable ETSI, disclosed, legal, contractual, and scheme rules.

  • Request record showing the subject, subscriber, requested public key, certificate profile, and reason for re-key.
  • Proof of possession or control for a non-CA-generated subject private key where clause 6.3.1 requires it.
  • Validation record for any changed certified name, organization, device, system, or other subject attribute.
  • Evidence that changed TSP terms and conditions were communicated and agreed to when applicable.
  • Audit logs for registration, certificate generation, certificate dissemination, and any related revocation decision.
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Question 3

When should re-key trigger revocation, notification, or CA key-change work?

A subject- can happen before expiry, after expiry, or after revocation. When compromise or another security breach drives the re-key, handle revocation separately from issuance of the new certificate: revocation requests and reports must be authenticated, processed on receipt, and reflected in status information within the maximum delay required by the CPS and ETSI EN 319 411-1. A clean re-key record cannot substitute for evidence that the compromised certificate was revoked.

Do not confuse subject- with . For CA certificate-signing keys, ETSI EN 319 411-1 requires a new CA certificate to be generated and distributed before expiry when the service continues, recommends a suitable interval for affected parties to prepare, and requires a documented CA key-pair generation procedure and ceremony evidence.

  • If the old certificate was revoked for key compromise, keep the revocation request, authentication, decision, status-publication evidence, and subscriber or subject notification record.
  • If cryptography or associated parameters become insufficient for remaining use, inform subscribers and relying parties with whom the TSP has relationships and make the information available to other relying parties.
  • For , keep the documented ceremony procedure, participating roles, responsibilities, collected evidence, and ceremony report.
  • For subject keys generated by the CA, preserve evidence that delivery protected secrecy and integrity and that copies were deleted after delivery except where escrow or recovery rules apply.
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