Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

[Aaron Gable]

Ballot SC-099: Improve Recording of Validation Methods

Summary of the Ballot

Remove ambiguous language from Section 3.2.2.4 and 3.2.2.5 requiring that CAs "record" the "relevant BR version number" when performing validation.

Replace this with unambiguous language in Section 5.4.1, requiring that CAs specifically audit log the information being validated and what validation method they are using to do so.

The new language has an Effective Date of July 15, 2026, giving CAs two months from the expected end of this ballot's IPR period to comply.

Background of the Ballot

The current BRs contain the following text in Sections 3.2.2.4 and 3.2.2.5:

> CAs SHALL maintain a record of which [domain/IP] validation method, including relevant BR version number, they used to validate every [domain/IP Address].

This text is problematic for four reasons:
- it only applies to domains and IP addresses, not other things being validated like organization information;
- the requirement to "maintain a record" is unclear (in audit logs? in a database? in a document?);
- no one is sure what the "relevant BR version" is (the effective version when the validation happened? the version that the validation process believes it implements?); and
- the text is not in Section 5.4.1, which is where the BRs concentrate requirements about recording information.

To resolve these issues, we need to start from first principles. The goal, as evidenced by discussion when this requirement was introduced and recollections of CA/BF members who were participating at the time, is to ensure that CAs and auditors are able to definitively identify the validation process with which the CA was required to comply for any given validation.

To determine what rules governed any given validation, we need two pieces of information:
1. When they performed that validation. The current requirements in Section 5.4.1 already require the CA to audit log the time of every verification procedure.
2. What validation method the CA used. This ballot augments Section 5.4.1 to also require that the CA audit log the validation method used, as well as other useful information.

Because we can accomplish the goal with a small addition to Section 5.4.1, this ballot removes the current text from Sections 3.2.2.4 and 3.2.2.5.

Note that this ballot removes the requirement to "record" the "relevant BR version number". This is not considered a loss, for several reasons:
- No CA or auditor should be relying on a logged BR version number to determine which version of the BRs governed the validation. The logged version number is not enforceable; the only information which can be relied upon to map a validation to a BRs version is the time at which the validation was performed.
- If a new version of the BRs adds requirements to a validation method, but gates those new requirements behind a future effective date, the logged version number may indicate that the CA complies with that new version long before the CA has actually implemented the soon-to-be-required behavior.
- If a new version of the BRs adds requirements to a validation method immediately upon the new version becoming effective, then a CA must update their processes to comply before the new version of the BRs is even published, and therefore the logged version number will be out-of-date compared to the implemented behavior.
- Part of the original motivation behind these statements was to encourage CAs to actually read new versions of the BRs and ensure their processes comply with them. We now have other mechanisms to encourage this behavior, such as CCADB self-assessments.

Therefore we conclude that recording the relevant BRs version number is neither useful nor well-specified, and therefore should not be included in the BRs.

This issue was discussed on Mozilla dev-security-policy@ (https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/x4zRcboSDwU) as well as at the CA/BF Face-to-Face Meeting 67 in Houston on March 10, 2026. The conclusion of those discussions was that we should create this ballot. The discussion period thread for this ballot can be seen here: https://groups.google.com/a/groups.cabforum.org/g/servercert-wg/c/KnkGWHEhWAI/m/juiAtWOJBwAJ

This ballot is written by Aaron Gable (ISRG / Let's Encrypt) and endorsed by Gurleen Grewal (Google Trust Services), Trev Ponds-White (Amazon Trust Services), and Roman Fischer (SwissSign).

--- Motion Begins ---

Modify the "Baseline Requirements for the Issuance and Management of Publicly-Trusted Server Certificates", based on Version 2.2.6, per the following redline:

https://github.com/cabforum/servercert/compare/168e0aa8cafe753c85a94b5a8f28541beda48201...e3fc28ab09ffae2f83aa9316ff20108199c29692

--- Motion Ends ---

This ballot proposes a Final Maintenance Guideline. The procedure for approval of this ballot is as follows:

Discussion (at least 7 days):

• Start time: 2026-04-03 19:00 UTC
• End time: 2026-04-10 19:00 UTC

Vote for approval (7 days):

• Start time: 2026-04-10 19:30 UTC
• End time: 2026-04-17 19:30 UTC

[Michael Guenther]

[Pedro FUENTES]

OISTE votes yes to SC-99

 

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WISeKey SA

Pedro Fuentes
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[Tugba ÖZCAN (BILGEM KSM)]

Kamu SM votes Yes on Ballot SC-099.

   

 

Tuğba ÖZCAN
TÜBİTAK BİLGEM

Kamu Sertifikasyon Merkezi/E-İmza Teknolojileri Birim Yöneticisi

tugba...@tubitak.gov.tr, +90 262 648 18 18 - 8543

bilgem.tubitak.gov.tr | Sorumluluk Reddi                 

   

---

Kimden: "'Aaron Gable' via Server Certificate WG (CA/B Forum)" <server...@groups.cabforum.org>
Kime: "servercert-wg" <server...@groups.cabforum.org>
Gönderilenler: 10 Nisan Cuma 2026 22:30:17
Konu: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

--

[Aaron Gable]

Let's Encrypt / ISRG votes Yes on Ballot SC-099.

To view this discussion visit https://groups.google.com/a/groups.cabforum.org/d/msgid/servercert-wg/1760763618.26109370.1776084838064.JavaMail.zimbra%40tubitak.gov.tr.

[Scott Rea]

eMudhra Votes YES to Ballot SC-099

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>
Date: Friday, 10 April 2026 at 2:30 PM
To: server...@groups.cabforum.org <server...@groups.cabforum.org>
Subject: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

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[Trevoli Ponds-White]

Amazon Trust Services votes Yes

[Ben Wilson]

Mozilla votes "Yes" on Ballot SC-099.

--

[Chad Dandar (cdandar)]

Cisco votes "Yes" on Ballot SC-099.

 

Chad Dandar

Cisco

--

[Hogeun Yoo]

NAVER Cloud Trust Services votes "Yes" on Ballot SC-099

Best Regards,

Hogeun Yoo

-----Original Message-----
From: "'Aaron Gable' via Server Certificate WG (CA/B Forum)"<server...@groups.cabforum.org>

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[黃晟(orca)]

TWCA votes Yes on Ballot SC-099.

 

 

Best,

 

Sean Huang

Senior PKI Compliance Engineer
TEL：02-2370-8886#728
FAX：02-2388-6720
Email：or...@twca.com.tw

10F., No. 85, Yanping South Road,

Taipei, Taiwan (R.O.C.)

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[Adriano Santoni]

Actalis votes "Yes" on Ballot SC-099.

Il 10/04/2026 21:30, 'Aaron Gable' via Server Certificate WG (CA/B Forum) ha scritto:

External sender. Verify for authenticity before opening any links or attachments.

[Josselin ALLEMANDOU]

CERTIGNA votes « Yes » on ballot SC-099.

 

 

 

 

De : 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>
Envoyé : vendredi 10 avril 2026 21:30
À : server...@groups.cabforum.org
Objet : [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

 

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[Backman, Antti]

Telia vote ‘Yes’ on Ballot SC-099.

//Antti

[Dimitris Zacharopoulos (HARICA)]

HARICA votes "yes" to ballot SC099.

[jun....@cybertrust.co.jp]

Cybertrust Japan votes ‘Yes’ on SC-099

-----Original Message-----
From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Sent: Saturday, April 11, 2026 4:30 AM
To: server...@groups.cabforum.org
Subject: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

Ballot SC-099: Improve Recording of Validation Methods


Summary of the Ballot


Remove ambiguous language from Section 3.2.2.4 and 3.2.2.5 requiring that CAs "record" the "relevant BR version number" when performing validation.

Replace this with unambiguous language in Section 5.4.1, requiring that CAs specifically audit log the information being validated and what validation method they are using to do so.

The new language has an Effective Date of July 15, 2026, giving CAs two months from the expected end of this ballot's IPR period to comply.

Background of the Ballot

The current BRs contain the following text in Sections 3.2.2.4 and 3.2.2.5 <http://3.2.2.5/> :

* Start time: 2026-04-03 19:00 UTC
* End time: 2026-04-10 19:00 UTC

Vote for approval (7 days):

* Start time: 2026-04-10 19:30 UTC
* End time: 2026-04-17 19:30 UTC

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[郭宗閔]

Chunghwa Telecom votes "Yes" on Ballot SC-099.

 

 

Regards,

Tsung-Min Kuo

Chunghwa Telecom Co., Ltd., Taiwan (R.O.C.)

 

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Sent: Saturday, April 11, 2026 3:30 AM
To: server...@groups.cabforum.org

Subject: [外部郵件][Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

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[Wayne Thayer]

Fastly votes Yes on ballot SC-099.

- Wayne

--

[大野 文彰]

SECOM Trust Systems votes YES on Ballot SC-099.

 

Best regards,

 

ONO Fumiaki / 大野 文彰

(Japanese name order: family name first, in uppercase)

SECOM Trust Systems CO., LTD.

 

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Sent: Saturday, April 11, 2026 4:30 AM
To: server...@groups.cabforum.org

--

[Nome Huang]

TrustAsia votes “Yes” on SC-099.

[Yoshihiko Matsuo]

JPRS votes YES on Ballot SC-099.

Yoshihiko Matsuo(JPRS)

On Fri, 10 Apr 2026 12:30:17 -0700
"'Aaron Gable' via Server Certificate WG (CA/B Forum)" <server...@groups.cabforum.org> wrote:

> Ballot?SC-099: Improve Recording of Validation Methods

>
> Summary of the Ballot
>
>
> Remove ambiguous language from Section 3.2.2.4 and 3.2.2.5 requiring that CAs "record" the "relevant BR version number" when performing validation.
>
>
> Replace this with unambiguous language in Section 5.4.1, requiring that CAs specifically audit log the information being validated and what validation method they are using to do so.
>
>
> The new language has an Effective Date of July 15, 2026, giving CAs two months from the expected end of this ballot's IPR period to comply.
>
>
> Background of the Ballot
>
>

> The current BRs contain the following text in Sections 3.2.2.4 and?<http://3.2.2.5/>3.2.2.5:

>
> > CAs SHALL maintain a record of which [domain/IP] validation method, including relevant BR version number, they used to validate every [domain/IP Address].
>
> This text is problematic for four reasons:
> - it only applies to domains and IP addresses, not other things being validated like organization information;
> - the requirement to "maintain a record" is unclear (in audit logs? in a database? in a document?);
> - no one is sure what the "relevant BR version" is (the effective version when the validation happened? the version that the validation process believes it implements?); and
> - the text is not in Section 5.4.1, which is where the BRs concentrate requirements about recording information.
>
> To resolve these issues, we need to start from first principles. The goal, as evidenced by discussion when this requirement was introduced and recollections of CA/BF members who were participating at the time, is to ensure that CAs and auditors are able to definitively identify the validation process with which the CA was required to comply for any given validation.
>
> To determine what rules governed any given validation, we need two pieces of information:
> 1. When they performed that validation. The current requirements in Section 5.4.1 already require the CA to audit log the time of every verification procedure.
> 2. What validation method the CA used. This ballot augments Section 5.4.1 to also require that the CA audit log the validation method used, as well as other useful information.
>
> Because we can accomplish the goal with a small addition to Section 5.4.1, this ballot removes the current text from Sections 3.2.2.4 and 3.2.2.5.
>
> Note that this ballot removes the requirement to "record" the "relevant BR version number". This is not considered a loss, for several reasons:
> - No CA or auditor should be relying on a logged BR version number to determine which version of the BRs governed the validation. The logged version number is not enforceable; the only information which can be relied upon to map a validation to a BRs version is the time at which the validation was performed.
> - If a new version of the BRs adds requirements to a validation method, but gates those new requirements behind a future effective date, the logged version number may indicate that the CA complies with that new version long before the CA has actually implemented the soon-to-be-required behavior.
> - If a new version of the BRs adds requirements to a validation method immediately upon the new version becoming effective, then a CA must update their processes to comply before the new version of the BRs is even published, and therefore the logged version number will be out-of-date compared to the implemented behavior.
> - Part of the original motivation behind these statements was to encourage CAs to actually read new versions of the BRs and ensure their processes comply with them. We now have other mechanisms to encourage this behavior, such as CCADB self-assessments.
>
> Therefore we conclude that recording the relevant BRs version number is neither useful nor well-specified, and therefore should not be included in the BRs.
>

> This issue was discussed on Mozilla dev-security-policy@ (https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/x4zRcboSDwU) as well as at the CA/BF Face-to-Face Meeting 67 in Houston on March 10, 2026. The conclusion of those discussions was that we should create this ballot. The discussion period thread for this ballot can be seen here:?https://groups.google.com/a/groups.cabforum.org/g/servercert-wg/c/KnkGWHEhWAI/m/juiAtWOJBwAJ

>
> This ballot is written by Aaron Gable (ISRG / Let's Encrypt) and endorsed by Gurleen Grewal (Google Trust Services), Trev Ponds-White (Amazon Trust Services), and Roman Fischer (SwissSign).
>
>
> --- Motion Begins ---
>
>
> Modify the "Baseline Requirements for the Issuance and Management of Publicly-Trusted Server Certificates", based on Version 2.2.6, per the following redline:
>
>
> https://github.com/cabforum/servercert/compare/168e0aa8cafe753c85a94b5a8f28541beda48201...e3fc28ab09ffae2f83aa9316ff20108199c29692
>
>
> --- Motion Ends ---
>
>
> This ballot proposes a Final Maintenance Guideline. The procedure for approval of this ballot is as follows:
>
>
> Discussion (at least 7 days):

> Start time: 2026-04-03 19:00 UTCEnd time: 2026-04-10 19:00 UTC

> Vote for approval (7 days):
>

> Start time: 2026-04-10 19:30 UTCEnd time: 2026-04-17 19:30 UTC

>
>
>
> --
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[sde...@godaddy.com]

GoDaddy votes Yes on Ballot SC-099.

 

Regards,

Steven Deitte

 

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>
Date: Friday, April 10, 2026 at 3:30 PM
To: server...@groups.cabforum.org <server...@groups.cabforum.org>
Subject: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

Ballot SC-099: Improve Recording of Validation Methods Summary of the Ballot Remove ambiguous language from Section 3. 2. 2. 4 and 3. 2. 2. 5 requiring that CAs "record" the "relevant BR version number" when performing validation. 

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[Alvin Wang]

SHECA votes Yes on Ballot SC-099.

Regards,

Alvin.Wang

On Saturday, April 11, 2026 at 3:30:33 AM UTC+8 aa...@letsencrypt.org wrote:

[Tom Zermeno]

SSL.com votes “YES” on SC-099.

• Tom Z. 

• SSL.com

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Date: Friday, April 10, 2026 at 2:30 PM
To: server...@groups.cabforum.org <server...@groups.cabforum.org>
Subject: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

[Adriano Santoni]

Actalis votes 'yes' on ballot SC-099

Il 10/04/2026 21:30, 'Aaron Gable' via Server Certificate WG (CA/B Forum) ha scritto:

External sender. Verify for authenticity before opening any links or attachments.

[Mrugesh Chandarana]

IdenTrust votes Yes on this ballot. 

---

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Sent: Friday, April 10, 2026 12:30 PM
To: server...@groups.cabforum.org <server...@groups.cabforum.org>
Subject: [External][Possible SPAM][Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

 

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[Dustin Hollenback]

Apple votes “Yes” on Ballot SC-099.

[Chris Clements]

Google votes Yes on Ballot SC-099.

[qi_ji...@itrus.com.cn]

iTrusChina votes YES on Ballot SC-099.

---

qi_ji...@itrus.com.cn

[Kateryna Aleksieieva]

Certum votes YES on Ballot SC-099

 

Kind regards,

Kateryna Aleksieieva

[Peter Miškovič]

Disig votes „Yes“ on Ballot SC-099: Improve Recording of Validation Methods.

 

Regards,

Peter Miskovic

[Entschew, Enrico]

D-Trust votes „Yes“ on Ballot SC-099.

 

Thanks,

Enrico

[Arvid Vermote]

GlobalSign votes “Yes” on Ballot SC-099.

To view this discussion visit https://groups.google.com/a/groups.cabforum.org/d/msgid/servercert-wg/d0da9df2b7e3403bac49fe3201b24d7e%40disig.sk.

[Tim Hollebeek]

DigiCert votes YES on SC-099.

-Tim

To view this discussion visit https://groups.google.com/a/groups.cabforum.org/d/msgid/servercert-wg/CA%2B1gtaZ0QfOT2_Cb-%2B%3DnUufWg4xoM9bteOL4UZxnt3JCOsDBYA%40mail.gmail.com.

[Martijn Katerbarg]

Sectigo votes YES to Ballot SC-099

---

From: 'Aaron Gable' via Server Certificate WG (CA/B Forum) <server...@groups.cabforum.org>

Sent: Friday, April 10, 2026 9:30 PM

To: server...@groups.cabforum.org <server...@groups.cabforum.org>
Subject: [Servercert-wg] Voting Period Begins: Ballot SC-099: Improve Recording of Validation Methods

 

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