A clause-oriented map for certificate-service teams implementing ETSI EN 319 411-1 policies, CP/CPS commitments, registration, revocation, status services, and CA key controls.
Use it to structure implementation evidence for public-key certificate services. It does not supersede the ETSI standard or a conformity assessment.
ETSI EN 319 411-1 V1.5.1 defines general policy and security requirements for Trust Service Providers issuing public-key certificates, including trusted website certificates. This page helps turn the standard into an implementation map: identify the profile, link each service component to CP/CPS text, and collect evidence for registration, issuance, revocation, status services, repositories, subscriber terms, and CA key management. Its EN 319 401 reference is non-specific, so clause 2.1 makes the latest edition applicable; record the EN 319 401 edition and assessment date used.
1
Section 1
Start with the certificate policy profile
The first mapping decision is the profile. EN 319 411-1 distinguishes requirements that apply to any Certificate Policy (CP), conditional requirements, choice-based requirements, profile-marked requirements for LCP, NCP, NCP+, EVCP, OVCP, IVCP, and DVCP, and [WEB] requirements. Unless stated otherwise, NCP+ and EVCP inherit NCP requirements, while DVCP, OVCP, and IVCP inherit LCP requirements. A register that ignores those markings will overstate some duties and miss others.
For TLS/SSL website certificates, keep a separate bridge for CA/Browser Forum dependencies. EN 319 411-1 includes DVCP, OVCP, IVCP, and EVCP profiles that build on ETSI policies and refer to BRG or EVCG requirements. The ETSI map should identify those dependencies without pretending to restate the current CA/B Forum text.
Use the full policy name in the requirements register: Lightweight (LCP), Normalized Certificate Policy (NCP), Extended Normalized Certificate Policy (NCP+), Domain Validation Certificate Policy (DVCP), Organizational Validation Certificate Policy (OVCP), Individual Validation Certificate Policy (IVCP), or Extended Validation Certificate Policy (EVCP).
Record whether the service uses LCP, NCP, NCP+, EVCP, OVCP, IVCP, DVCP, or a custom CP defined under clause 7.
Mark each requirement row as unmarked, conditional, choice-based, profile-specific, or web-authentication certificate before assigning an owner.
For DVCP, OVCP, IVCP, and EVCP, add a dependency column for BRG or EVCG review instead of treating the ETSI PDF as the only source.
Tie the CP choice to certificate usage, subject type, certificate profile, relying-party audience, and any subscriber or subject restrictions.
Grounds the general trust-service policy baseline that EN 319 411-1 imports for CPS and TSP governance requirements.
General Policy Requirements for Trust Service Providers
2
Section 2
Map CP and CPS duties before operational controls
EN 319 411-1 uses the CP/CPS split as the backbone of the certificate-service requirements map. The CP says what rule set and certificate quality apply; the (CPS) says how the TSP operates the service to meet that policy. The requirements file should therefore link each operational control back to the CP and CPS clause that makes it auditable.
The CPS map should cover signature algorithms and parameters, certificate profiles, public online CPS disclosure, sensitive-information exclusions, and any BRG or EVCG monitoring obligations for public TLS/SSL profiles. Internal runbooks can support the CPS, but the public artifact should not expose private procedure names or confidential operational details.
Create one row per CP/CPS requirement with requirement ID, policy marker, public disclosure status, owner, evidence artifact, and review trigger.
Show how the CPS implements secure CA key management, registration, issuance, revocation, repository, and certificate status practices.
Keep certificate-profile requirements separate from subscriber terms so relying-party disclosures remain readable.
For public CPS disclosure, record the online publication location, version, effective date, and redaction rationale for sensitive details.
Grounds the general TSP policy framework referenced by EN 319 411-1 for practice statements and trust-service governance.
General Policy Requirements for Trust Service Providers
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Section 3
Map the certificate lifecycle service components
Clause 4.3 classifies certification services into registration, certificate generation, dissemination, revocation management, revocation status, and optional subject device provisioning. Use those components as the first column of the requirements map, then attach the applicable clause 5, clause 6, and clause 7 rows.
The map should make subscriber and subject evidence explicit. EN 319 411-1 requires terms and conditions before the contractual relationship, durable human-readable communication, recorded acceptance, and traceable ratification where the subscriber and subject relationship requires it. Clause 6.4.6 requires the clause 6.3.4 subscriber documentation and CA-managed key-lifecycle logs to be kept for at least seven years after the affected certificate ceases to be valid; other records need their own applicable and disclosed retention rule.
Registration: keep identity-validation method, subject attributes, RA handoff, proof-of-possession, and acceptance records by certificate profile.
Certificate generation and dissemination: link issuance approval, certificate profile, repository publication, and CA public-key distribution evidence.
Revocation management: record revocation requests, reports, decisions, status changes, subscriber or subject notification attempts, and any suspension handling.
Certificate status: preserve CRL or OCSP service evidence, 24/7 availability monitoring, integrity protection, consistency between methods, and public international reachability, unless the documented validity-assured certificate branch applies.
Subject device provisioning: map secure device preparation, key delivery, activation data separation, and revocation triggers when the CA generates subject keys.
Exceptions: map whether each profile can be revoked, the CPS and problem-reporting controls for any non-revocable group, and the status-service treatment of certificates carrying the validity assured extension.
Retention: assign each evidence class its governing period instead of applying the seven-year minimum to records that clause 6.4.6 does not name.
Grounds the certification-service components, subscriber acceptance records, revocation management requirements, and certificate-status service requirements.
The present document includes the provision of services for registration
4
Section 4
Map CA key-management and cryptographic controls
CA key-management rows need more than a policy citation. EN 319 411-1 requires secure generation of CA keys, including keys used by revocation and registration services; physically secured environments; trusted-role participation; at least dual control for certificate-signing key creation; ceremony procedures; and a report proving the ceremony followed the stated procedure.
The same map should cover secure cryptographic devices, key backup and recovery, device certification or equivalent assurance, lifecycle end, and activation data controls. For subject keys generated by the CA, add rows for algorithm fitness, secure storage before delivery, protected delivery, deletion after delivery where required, and revocation if unauthorized disclosure is discovered.
Secure device evidence: certification guidance or equivalent configuration, access-control settings, shipment and storage tamper controls, and retirement destruction records.
Dual-control evidence: trusted-role assignments, minimum authorized personnel list, backup and recovery logs, and activation-data split-control records.
CA key usage evidence: certificate signing and revocation-status signing purpose, end-of-life controls, and checks that CA keys are not used for unrelated purposes.
Subject-key evidence: generation algorithm, delivery channel, deletion record, secure device issuance, and revocation records if private-key exposure occurs.
Grounds the CA key-generation, key ceremony, secure cryptographic device, dual-control, key-use, backup, recovery, and subject-key provisioning requirements.
The TSP shall generate CA keys
5
Section 5
Add custom policy and disclosure requirements
If a TSP defines a CP other than the clause 5 policies, clause 7 changes the requirements map. The CP must identify the EN 319 411-1 policy it adopts as a basis, state variances, and have an approving authority such as a policy management authority. A risk assessment should evaluate the requirements for the stated community and applicability, and a defined review process should ensure that the CP is supported by the CA's CPS.
Disclosure belongs in the same map. Informative Annex A's model PKI disclosure statement does not supersede the CP or CPS or create additional normative requirements. It illustrates what relying parties and subscribers may need in plain language: TSP contact information, certificate type and validation procedures, usage limits, subscriber obligations, status-checking obligations, liability limits, applicable agreements, and audit or trust-list references where applicable.
For a custom CP, record the base ETSI policy, added constraints, variances, policy authority, approval evidence, and risk assessment summary.
Map clause 5 and 6 unmarked requirements into the custom CP, then document which base-policy requirements, additions, or permitted variances apply.
Include X.509 certificate-profile requirements and the object identifier assigned to the custom CP.
Update subscriber and relying-party materials when custom policy changes add constraints or obligations.
Use a PKI disclosure statement to summarize the CP/CPS for users, but keep it linked back to the governing documents.
Grounds the scope, policy-profile markings, CP/CPS model, certification-service components, subscriber acceptance, revocation and status-service controls, CA key controls, and custom CP framework.
Grounds the policy-profile markings, LCP/NCP/NCP+/EVCP/OVCP/IVCP/DVCP profiles, [WEB] requirements, and BRG/EVCG dependency boundary.
Grounds the CP/CPS distinction, CPS structure expectation, signature algorithm disclosure, certificate profile references, and online CPS publication requirement.
Show 3 more
Grounds the certification-service components, subscriber acceptance records, revocation management requirements, and certificate-status service requirements.
Grounds the CA key-generation, key ceremony, secure cryptographic device, dual-control, key-use, backup, recovery, and subject-key provisioning requirements.
Grounds the clause 7 framework for custom certificate policies and Annex A's PKI disclosure statement model.
"Policy and security requirements for Trust Service Providers issuing certificates"
More quoted passages
"The CPS describes how the TSP operates its service"
"The present document includes the provision of services for registration"
"The TSP shall generate CA keys"
"Framework for the definition of other certificate policies"
Grounds the current general TSP policy baseline referenced without a version number by EN 319 411-1 for practice statements, governance, evidence, and supply-chain controls.
Grounds the general trust-service policy baseline that EN 319 411-1 imports for CPS and TSP governance requirements.
Grounds the general TSP policy framework referenced by EN 319 411-1 for practice statements and trust-service governance.
"General Policy Requirements for Trust Service Providers"