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Ballot SC038: Alignment of Record Archival

This ballot failed to go to a vote and failed pursuant to the Bylaws.

This begins the discussion period for Ballot SC38: Alignment of Record Archival (which I circulated a little while ago).

The following ballot is proposed by Neil Dunbar of TrustCor Systems and endorsed by David Kluge of Google Trust Services and Ben Wilson of Mozilla.

Purpose of Ballot:

After the updated language included in SC28 Sections 5.4.3 and 5.5.2 (of the BRs) could be in conflict. Section 5.5.2 requires all documentation relating to certificate requests and the verification thereof, and all Certificates and revocation thereof be retained for seven years after certificates cease to to be valid. Section 5.4.3 requires all audit logs of Subscriber Certificate lifecycle management event records be maintained for two years after the revocation or expiration of the Subscriber Certificate. These sections intersect at the retention requirements for audit logs and archived records, as they relate to subscriber certificate lifecycle events. The retention periods are in conflict as to the length of retention.

The proposed changes seek to bring these two sections of the “Baseline Requirements” into agreement and avoid confusion and potential issues of noncompliance as they relate to retention periods.

The NetSec discussion document for this ballot is attached as a PDF to this email.

Motion begins

Delete the following Section 5.5.2 Retention period for archive from the “Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates”, which currently reads as follows:

The CA SHALL retain all documentation relating to certificate requests and the verification thereof, and all Certificates and revocation thereof, for at least seven years after any Certificate based on that documentation ceases to be valid. Insert, as Section 5.5.2. Retention period for archive of the “Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates”, the following:

The CA SHALL retain all documentation relating to certificate requests and the verification thereof, and all Certificates and revocation thereof, for at least two years after any Certificate based on that documentation ceases to be valid.

Motion ends

* WARNING *: USE AT YOUR OWN RISK. THE REDLINE BELOW IS NOT THE OFFICIAL VERSION OF THE CHANGES (CABF Bylaws, Section 2.4(a)):

A comparison of the changes can be found at: https://github.com/cabforum/documents/compare/8f63128…neildunbar:180341b

This ballot proposes one Final Maintenance Guideline.

The procedure for approval of this ballot is as follows:

Discussion: (7+ days) Start Time: 2020-12-09 17:00 UTC End Time: not before 2020-12-16 17:00 UTC

Vote for approval: (7 days) Start Time: TBD End Time: TBD

Latest releases
Server Certificate Requirements
SC098: Process RFC 8657 CAA Parameters - Jun 16, 2026

Code Signing Requirements
v3.8 - Aug 5, 2024

What’s Changed CSC-25: Import EV Guidelines to CS Baseline Requirements by @dzacharo in https://github.com/cabforum/code-signing/pull/38 Full Changelog: https://github.com/cabforum/code-signing/compare/v3.7...v3.8

S/MIME Requirements
v1.0.15 - Ballot SMC017v2 - Jul 30, 2026

This ballot increases the minimum RSA key size for Root and Subordinate CA certificates in the S/MIME BRs from 2048 to 4096 bits for keys created after September 15, 2026, while retaining the 2048-bit minimum for Subscriber certificates. The ballot further requires that by September 15, 2027, CAs SHALL NOT issue Subscriber certificates from any Sub-CA whose RSA key modulus is less than 3072 bits, effectively sunsetting issuance from legacy 2048-bit Sub-CAs. The ballot also includes minor typographic corrections. This ballot is proposed by Martijn Katerbarg (Sectigo) and endorsed by Ben Wilson (Mozilla) and Stephen Davidson (DigiCert)

Network and Certificate System Security Requirements
Version 2.0.5 (Ballot NS-008) - Jul 9, 2025

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