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Artifact FAQGLOBALETSI EN 319 411-1

ETSI EN 319 411-1 Subscriber agreements

A focused answer on what certificate authorities and trust service providers need to put in place before a certificate accepts terms.

Based on ETSI EN 319 411-1 and ETSI EN 319 401 source material. Use it as implementation guidance, not for legal interpretation.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
4 sections2 primary sources
Overview

Before a enters a relationship covered by ETSI EN 319 411-1 V1.5.1 (April 2025), the TSP must communicate the certificate terms and conditions in a durable, human-readable way, record the agreement, and keep evidence that the subscriber accepted those terms by a traceable, wilful act. The standard supplies a technical and contractual baseline. Applicable consumer, electronic-transactions, trust-services, data-protection, scheme, and national rules can add form, language, consent, retention, or withdrawal requirements.

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4 of 4 questions
Question 1

What does ETSI EN 319 411-1 require before a subscriber agreement?

The CA or TSP should start with the terms and conditions that explain certificate use, acceptance, obligations, and limitations. ETSI EN 319 411-1 clause 6.3.4 requires the to be informed of those terms before the contractual relationship is formed.

The agreement process also needs to be usable as evidence later. The terms must be communicated through a durable means, in human-readable form, before the agreement. Electronic transmission is allowed, but the record must still show what version was presented and how acceptance occurred.

  • Identify the certificate policy, CPS, terms and conditions, and any PKI disclosure statement that govern the relationship.
  • Present the applicable terms before the enters the contractual relationship or accepts the certificate.
  • Use a durable communication method that preserves the terms with integrity over time and is readable by the .
  • Define what constitutes certificate acceptance in the terms and conditions, rather than leaving acceptance implied by operational workflow.
Recommended next step

Map ETSI EN 319 411-1 agreement evidence to your CA workflow

This FAQ helps check that subscriber onboarding, subject consent, certificate acceptance, publication choices, and retention records are captured in the same evidence trail.

Assessment workflow
Assess certificate controls

Review subscriber-agreement controls against CP, CPS, registration, and archival evidence.

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Research workflow
Research a scoped clause question

Resolve subscriber, subject, publication, or retention questions against cited ETSI source text.

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Talk to Sorena
Talk through implementation

Review CA onboarding evidence, agreement acceptance records, and the next control updates with Sorena.

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Question 2

How should the agreement handle subscribers and subjects?

ETSI EN 319 411-1 distinguishes the from the certificate . If the subscriber and subject are separate entities and the subject is a natural or legal person, the agreement shall be in two parts: one ratified by the subscriber and one ratified by the subject. The two parts may be ratified together when the subscriber is the subject legal person's official representative, or when the same official representative acts for both subscriber and subject.

That distinction matters for enterprise and delegated-certificate scenarios. The part should capture subscriber obligations, any secure-device requirement, consent to registration and revocation records, publication choices, and confirmation that certificate information is correct. The part should capture the subject obligations, secure-device acceptance where relevant, and consent to the records kept by the TSP.

  • Use a two-part agreement when the and are separate and the subject is a natural or legal person.
  • Use a such as signing or checking an acceptance box for each required ratification; an agreement may be electronic.
  • When the and are the same entity, or the subject is a device, include the subscriber and subject items in one or two agreement parts.
  • Allow staged acceptance only where the record still shows each accepted element, such as later confirmation that certificate information is correct.
Question 3

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 to be recorded, and, where the subscriber and 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 agreement, plus specific choices in the agreement such as consent to certificate publication.

  • Retain the signed or electronically accepted 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 as part of the terms and conditions, and for at least the clause 6.4.6 minimum where that clause applies.
Question 4

Questions and answers

What has to happen before a agreement is accepted?

The TSP must inform the of the terms and conditions before entering into the contractual relationship, communicate those terms through a durable means in human-readable form, and define what counts as acceptance. ETSI EN 319 411-1 also allows the terms to be transmitted electronically.

When do and agreements need two parts?

If the and are separate entities and the subject is a natural or legal person, the agreement shall be in two parts. The subscriber ratifies the first and the subject ratifies the second by a . They may ratify both together when the subscriber is the subject legal person's official representative, or the same official representative acts for both parties.

What evidence should be retained for a agreement?

The TSP must record the agreement with the and, when required, the . Keep the accepted terms version, the traceable acceptance act, and specific registration choices. Clause 6.3.4 says the records are retained for the period disclosed to the subscriber, while clause 6.4.6 sets a minimum of seven years after any certificate based on the clause 6.3.4 documentation ceases to be valid. The disclosed period and archive schedule must satisfy both rules.

Primary sources

References and citations

ETSI EN 319 411-1 V1.5.1 certificate policy and security requirements
etsi.org4 citations
Referenced sections
  • Primary source for certificate acceptance, subscriber and subject agreement structure, traceable acceptance, electronic agreement form, and retention requirements.
  • Clause 6.3.4 supports the pre-contract notice, durable communication, certificate-acceptance, and recorded-agreement requirements summarized here.
  • Requirements REG-6.3.4-09 through REG-6.3.4-13 support the split-agreement approach for separate subscribers and subjects.
Show 1 more
  • Requirements REG-6.3.4-07, REG-6.3.4-08, and REG-6.3.4-17 support recorded acceptance and disclosed retention; REG-6.4.5-04 covers the subscriber agreement's storage location, and clause 6.4.6 sets the seven-year minimum for the clause 6.3.4 documentation it covers.
"The agreement may be in electronic form"
More quoted passages
"The TSP shall communicate the terms and conditions through a durable"
"the agreement shall be in 2 parts"
"including the subscriber agreement"
ETSI EN 319 401 V3.2.1 general policy requirements for TSPs
etsi.org2 citations
Referenced sections
  • Supports the general policy baseline requiring subscribers and relying parties to receive precise terms and conditions before contracting.
  • Clause 6.2 supports the general TSP requirement to inform subscribers and relying parties of precise terms before a contractual relationship.
"Terms and conditions shall be made available through a durable means"
More quoted passages
"Subscribers and parties relying on the trust service shall be informed"

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