News from the Council of Accredited Conformity Assessment Bodies (ACAB-c) on Harmonized audit attestation presented by Philipp Bouchet from ACABc Member LSTI France and Mattias Wiedenhorst ACABc Member TÜVIT
Arno FiedlerOwner, Nimbus Technologieberatung GmbH
1. News from the Council of Accredited
Conformity Assessment Bodies (ACAB-c)
–
Harmonized audit attestation
and other topics
CA/B Forum Meeting – March 8th, 2018
Washington
2. 2
CA/B Forum Meeting –
Washington March 8th, 2018
Voluntary
Membership
Accredited Conformity Assessment Bodies:
Conformity assessment bodies (CABs) accredited by
a EA or IAF member according to ISO/IEC 17065 +
eIDAS Art. 3 No. 18 scope of accreditation in the area
of electronic identification and trust services for
electronic transactions
Supporting Parties:
Organization who are directly or indirectly affected
by accredited CABs and their work: trust service
provider (TSP), supervisory bodies (SB), European
Standards Organizations (ESO), the CA/B-Forum and
manufacturers of technical equipment used by TSP.
ACAB’Council
3. 3
CA/B Forum Meeting –
Washington March 8th, 2018
Council of ISO/IEC 17065 accredited CABs
• Setup and maintain an ACAB’c “Code of Conduct”
• Information exchange
• Interpretation of standards
• Communication to third parties
• Publish a list of member CABs
• Provide a recognition mark
Main
Objectives
ACAB’Council
4. 4
CA/B Forum Meeting –
Washington March 8th, 2018
February 8th, 2018 - Paris
• New ACAB’c template for audit attestation letter
approved
• New member KPMG Switzerland
• New member candidates APCER, ASIT, Datenschutz
cert, TCAB
• New Board approved
Meetings
ACAB’Council
5. 5
CA/B Forum Meeting –
Washington March 8th, 2018
Philippe Bouchet – Chairman
Matthias Wiedenhorst – Vice Chairman
Armelle Trotin – General secretary
Board
ACAB’Council
6. 6
CA/B Forum Meeting –
Washington March 8th, 2018
• First version introduced and agreed during Bilbao F2F meeting 2016
• Missing items (e.g. citation of the audited TSP policy documents) had
since then been added independently by the different members
• Some information was still felt to be “hidden” within the attestation
• New version of the audit attestation template has been approved during
Paris meeting
Harmonized ETSI Audit Attestation
7. 7
CA/B Forum Meeting –
Washington March 8th, 2018
Harmonized ETSI Audit Attestation
Attestation Date & “Clean audit” statement
CAB contact information
8. 8
CA/B Forum Meeting –
Washington March 8th, 2018
Harmonized ETSI Audit Attestation
Identification of CAB and TSP
Identification of Root CA
9. 9
CA/B Forum Meeting –
Washington March 8th, 2018
Harmonized ETSI Audit Attestation
Audit type, Dates, Standards used
CP / CPS documents covered
10. 10
CA/B Forum Meeting –
Washington March 8th, 2018
Harmonized ETSI Audit Attestation
Sub-CA Details
11. 11
CA/B Forum Meeting –
Washington March 8th, 2018
• Separate Attestation for each Root CA
• Required information are pointed out
more explicitly
• ACAB’c template is available and can be
used right now
• Was given as input to ETSI EN 319 403
template to harmonize form and content
Harmonized ETSI Audit Attestation
12. 12
CA/B Forum Meeting –
Washington March 8th, 2018
• Seeking for further input from consumers
(e.g. ALV issues) in order to make
attestations as comfortable as possible
Harmonized ETSI Audit Attestation
13. 13
CA/B Forum Meeting –
Washington March 8th, 2018
• Possibilities around ETSI Audit Attestation
• No mandatory requirement, but CA’s could be encouraged to require
attestations derived from one of the templates from their CAB
• Attestation template to be amended to ETSI EN 319 403 could be
made mandatory by CABF
• ACAB’c attestation template could be made mandatory by CABF
Harmonized ETSI Audit Attestation
14. 14
CA/B Forum Meeting –
Washington March 8th, 2018
• No mandatory requirement, but CA’s could be encouraged to require
attestations derived from one of the templates from their CAB
• Pro
• Flexibility for CA’s and CAB’s
• Con
• No mandatory template, root program operators will still have to
deal with individual attestations
Harmonized ETSI Audit Attestation
15. 15
CA/B Forum Meeting –
Washington March 8th, 2018
• Attestation template to be amended to ETSI EN 319 403 could be made
mandatory by CABF
• Pro
• Publically available to all CAB’s
• Con
• Publically available to all CAB’s, root store operators would have to
check accreditation
• Due to normative procedures, changes to the template would
require a rather long time period (~ 1 year)
Harmonized ETSI Audit Attestation
16. 16
CA/B Forum Meeting –
Washington March 8th, 2018
• ACAB’c attestation template could be made mandatory by CABF
• Pro
• Fast adaption of the template in case of requested changes
• Only available to ACAB’C members, hence only to duly accredited
CAB’s
• Con
• Only available to ACAB’c members => CAB’s need to join ACAB’c
Harmonized ETSI Audit Attestation
17. 17
CA/B Forum Meeting –
Washington March 8th, 2018
• Topics that have popped up in real life
• Not enough for a CA to say “The auditor must take care of everything.”
• CA’s are responsible to request the correct audit from their auditor and to
provide the required information for a correct audit attestation
• Point-in-time vs. period of time
• Date issues
Other topics – CA’s & Auditors
18. 18
CA/B Forum Meeting –
Washington March 8th, 2018
• Language of BR is unambiguous
• Point-in-time before issuing the first PTC certificate
• unbroken sequence of audit periods after that
• In case the CA changes its auditor, the new auditor still has to perform a
period-of-time audit
• Point-in-time only if the CA is audited “for the first time…”
• Not, if the CA is audited “for the first time by this auditor…”
Point-in-time vs. Period-of-time
19. 19
CA/B Forum Meeting –
Washington March 8th, 2018
• Audit dates
• period during which the audit is performed
• Audit period dates
• period of time for which the operation of the CA is assessed
• Audit attestation date
• Date on which the audit attestation is issued
Date issues
20. 20
CA/B Forum Meeting –
Washington March 8th, 2018
• Should be obvious, but real life shows that it might be worth mentioning
• Audit periods must not be longer than one year (“365 days”)
• Audit periods may overlap, but there must not be uncovered days
between two consecutive periods
• End of the audit period must not be after end of the audit
• Attestation date must not be before end of the audit
Date issue
21. 21
CA/B Forum Meeting –
Washington March 8th, 2018
Philippe Bouchet
ACAB’c Chairman
LSTI
pbouchet@lsti.fr
Matthias Wiedenhorst
ACAB‘c Vice-Chairman
TUV Informationstechnik GmbH
TUV NORD GROUP
m.wiedenhorst@tuvit.de
22. 22
CA/B Forum Meeting –
Washington March 8th, 2018
The Accredited Conformity Assessment Bodies’
council
65, rue de Gergovie
75014 Paris – France
Secretariat Armelle Trotin + 33 (0)6 08 67 51 44
secretary@acab-c.com
For further information or in order to register, please contact us at:
www.acab-c.com