ETSI EN 319 411-2 QSCD Route

Start by separating the basic qualified-certificate policies from the QSCD policies. QCP-n and QCP-l cover EU qualified certificates for natural and legal persons. QCP-n-qscd and QCP-l-qscd add the requirement that the private key related to the certified public key resides in a QSCD.

That distinction matters because EN 319 411-2 treats the QSCD route as more than a certificate label. The route changes the applicable policy baseline, certificate request checks, certificate profile content, CPS disclosures, and monitoring for device-status changes.

Before issuing under QCP-n-qscd or QCP-l-qscd, the TSP needs evidence that the device is certified as a QSCD, whether the device is prepared by the issuing TSP or by another party. The certificate request process also needs to show that the public key to be certified comes from a key pair generated by a QSCD.

Remote or delegated arrangements need extra attention. If a third-party TSP manages the device on behalf of the subject, the issuing TSP has to verify that the third-party TSP meets the appropriate qualification requirements. If the subject key pair is generated by a TSP and imported into the QSCD, the environmental assumptions and security objectives for the certified device have to remain met.

The certificate profile must match the selected route. For QCP-n-qscd and QCP-l-qscd certificates, EN 319 411-2 requires the QSCD qcStatement defined in ETSI EN 319 412-5. The same standard says that the QSCD qcStatement must not be included in certificates that are not issued according to QCP-n-qscd or QCP-l-qscd requirements.

The CP and subscriber-facing disclosure should also say plainly whether the policy is for EU qualified certificates and whether it requires use of a QSCD. This avoids a common mismatch: a certificate includes a QSCD signal while the CP, CPS, terms, or evidence pack cannot show the route and device checks behind it.

The QSCD route needs monitoring after issuance because the device status can change while certificates are still valid. EN 319 411-2 requires the TSP to take appropriate measures when QSCD status changes before the certificate validity period ends and to document those measures in the CPS.

The standard points to Member State notifications on designated bodies and certified QSCDs as a way to monitor status. It also notes that loss of QSCD certification status can trigger revocation for a non-expired certificate bearing the QSCD qcStatement because the change impacts certificate validity.

Use this checklist when reviewing a new qualified certificate profile, an existing CP/CPS, or an audit evidence pack for a QSCD route claim.