69473

WORLD BANK

REIMBURSABLE TECHNICAL ASSISTANCE

ITIDA

E-SIGNATURE AND PKI FRAMEWORKS:

INTERNATIONAL BENCHMARKS

FINAL REPORT

WORLD BANK
 TABLE OF CONTENTS

I. Executive
Summary ...........................................................................
............... 3
II. Summary of Findings &
Recommendations ...................................................... 5
III. Introduction &
Background ........................................................................
....... 6
IV. Overview of existing e-signature and PKI enabling environment in
Egypt ....... 8
A Legal
Framework .........................................................................
................. 8
B Institutional
Arrangements ......................................................................
....... 9
C Expected uses of e-signatures in
Egypt ...................................................... 11
V.
Benchmarking ......................................................................
.......................... 12
A Enabling Environment
issues ...................................................................... 12
B PKI Implementation
Issues ..........................................................................
23
VI. Recommendations for strengthening Egypt’s e-signature and PKI enabling

environment .......................................................................
.................................... 36
A As Root CA, ITIDA should develop certificate standards
policies ................ 36
applicable to Egypt, and can use its existing relationships with is
MoU .................. 36
partners in this
regard. ...........................................................................
................ 36
B Measures to limit the liability of ITIDA as Root
CA ....................................... 36
C Clarify which electronic transactions will be subject to
PKI .......................... 36
D Training for lawyers and judges on e-signatures
issues .............................. 37
E Introducing alternative dispute resolution processes for e-signature
matters37
F International
Considerations ....................................................................
.... 37
VII.
Glossary ..........................................................................
............................... 39
VIII.
Annexes ...........................................................................
.............................. 41
IX.
Bibliography.......................................................................
............................. 42

ANNEX
1 .................................................................................
.............................. 44
ANNEX
2 .................................................................................
.............................. 53
ANNEX
3 .................................................................................
.............................. 54
A United
States.............................................................................
................. 54
B State of Washington Pricing
(2003) ............................................................ 58

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 I. Executive Summary

This report provides background information and experiences from other

countries
relative to their adoption and implementation of Public Key Infrastructure (PKI)
electronic
authentication systems, with particular attention to the underlying enabling
environment and
factors affecting use and uptake.

PKI is one technique used to ensure the security of electronic transactions

and to
authenticate users. PKI uses public key cryptography and X.509 certificates and
provides a
high level of security for electronic transactions.

Every country approaches the use of e-signatures differently. Even in EU

Member States
operating under a common set of community-wide Directives, each Member State has a
different approach to use of e-signatures for official purposes, including PKI.
Because the
implementation of PKI is so situation-specific, meaningful apples-to-apples
“benchmark�?
comparisons are difficult.

These different approaches mean that there are different implementation

costs - as well as
benefits - derived from the use of PKI, depending, for example, on the modality
for issuing
certificates (Root CA vs. outsourced CAs), the scope of use of PKI, as well as the
systems
used to deliver the digital certificates (e.g., smart cards vs. simple electronic
file transfer).
Because some countries use PKI for limited purposes, comparing “costs�? with
countries that
chose to use PKI for more or broader purposes, or that use a different modality to
deliver
certificates, is difficult without discounting the full range of variables. Also,
the “cost�? of PKI
should take into account the benefits to be achieved through the use of PKI
systems.

In general, the single biggest cost is incurred in the establishment of the

certification
process. In the case of Root CAs (as is intended in Egypt) there is additional
incremental cost
for each certificate issued, but in other jurisdictions, this cost has been
negligible.

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 Where countries have limited use of PKI, it is usually linked implicitly to
a
“weak/strong�? signature application environment. “Strong�? signatures (using PKI
for
example), are appropriate for some on-line transaction activities, requiring a
high degree of
verification, while “weak�? signatures may be appropriate for others. The legal
regime in Egypt
contemplates such a differentiation, and the Government could consider which
applications
would be best suited for use of “strong�? signatures using PKI.

Realizing the benefits of PKI will depend in part on the trust of users in
the overall
system. In part this trust will be based on the enabling environment, including
the practices
and policies of the Root CA.

A summary of findings and recommendations can be found in Section II. These

recommendations are aimed at enhancing trust in the system, which should therefore
encourage
use. Clarifying the scope of application of PKI will be one factor affecting costs
(and
benefits).

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 II. Summary of Findings & Recommendations

 As Root CA, ITIDA should develop certificate standards policies applicable

to
Egypt, and can use its existing relationships with its MoU partners to
assist in
that regard.

 Consider measures to limit the liability of ITIDA as Root CA

 Clarify which types of electronic activities will be subject to PKI

(“electronic
signatures�? under Egyptian law) and which activities (“electronic
writings/documents�?) will not require PKI– allowing choice of
authentication
measure appropriate to the level of security desired.

 Consider training for lawyers and judges on e-signatures issues.

 Consider introducing alternative dispute resolution processes for e-

signature
matters.

 Consider introducing “party autonomy�? and reconcile with UNCITRAL

Convention on Electronic Contracting.

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 III. Introduction & Background

This report is being delivered pursuant to the agreement (Agreement)

between the
Ministry of Communications and Information Technology of the Arab Republic of
Egypt
(MCIT) and the World Bank (Bank) for the provision by the Bank of technical
assistance
(RTA) to MCIT and certain of its affiliates. One of those affiliates is the
Information
Technology Industry Development Authority (ITIDA).

The purpose of this report is analyze international benchmarks regarding

the enabling
environment for e-signatures and PKI frameworks validating Egypt’s existing and
emerging e-
signature/PKI initiatives and (ii) make recommendations regarding strengthening
the existing
e-signature/PKI enabling environment in Egypt.

As discussed further in this report, the method for authenticating users

of electronic
signatures chosen in Egypt is based on public/private key infrastructure (PKI),
although other
methods are contemplated in Egypt’s legal enabling framework. PKI uses
asymmetric
encryption (as distinguished from symmetric systems, where the “secret�?
(private) key is
known only to the party holding it, and that when matched with the “public
key�? (held by third
party) forms a “pair�? that ensure the authenticity of the data message. This
system involves a
3rd party to ensure that the encryption of the data message attached to the
signature has not
been corrupted1;

PKI is generally recognized as a preferred authentication method when

high levels of
certainty regarding the identity of the user are required.2

Other types of electronic authentication and their salient features are

summarized below :

1
Both the UNCITRAL model laws on e-Commerce and on Digital Signatures contemplate
the use of,
although are not based on the exclusive use of PKI mechanisms. PKI is well-suited
for “e-commerce�?
transactions among and between parties not known or with no prior relation to each
other.
2
ACN.9/630/Add.3 - Possible future work on electronic commerce Comprehensive
reference document
on elements required to establish a favorable legal framework for electronic
commerce: sample chapter
on international use of electronic authentication and signature methods, UNICTRAL,
available at:
http://daccessdds.un.org/doc/UNDOC/GEN/V07/822/59/PDF/V0782259.pdf?OpenElement
(UNCITRAL
Future Work).

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  symmetric encryption (pre-arranged shared cryptology where the same
“key�? is
used to encrypt a data message at the point of origin and decrypt it
at the receiving
end, the secrecy of which must be maintained by both parties;
 passwords (this is a symmetric process and a common application
is ATM
technology);
 tokens (these are like passwords, insofar as the “password�? is
embedded in the
“token�? – these can be either physical tokens (cards) or electronic
tokens);
 digital biometrics (such as retinal or other scanning requires agreed
protocols and
standards of hardware and software);
 secure closed systems (dedicated computer-to-computer links or
private
networks); and
 blended systems (for example, using one of the above digital
technologies
combined with an orthogonal confirmation, such as a telephone
confirmation).

This report focuses on the PKI experiences of other countries that use PKI.

Methodological Note: This report is based primarily on desk research and on

interviews
conducted with ITIDA over two missions in September 2006 and March 2007. Further,
telephone and email consultations were made with PKI administrators in Brazil and
Canada.

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 IV. Overview of existing e-signature and PKI enabling environment
in Egypt

This chapter reviews (i) the existing legal enabling framework for the
use of e-
signatures/PKI in Egypt, (ii) the key institutional arrangements (functions and
organization) of
ITIDA within this enabling framework, and (iii) the main purposes for which e-
signatures will
be used in Egypt.

A. Legal Framework

The legal framework that establishes the basis for legal recognition of
electronic
signatures in Egypt consists of two primary instruments – Law # 15 of 2004
Regulating E-
Signature and Establishing ITIDA (Law) and MCIT Decree # 109 of 2005 Issuing
Executive
Regulations of Law # 15 of 2004 (Decree).3

The Law establishes the legal functional equivalence of electronic

signatures and
electronic documents. The Law also establishes ITIDA and grants it certain
powers, inter alia,
in the area of e-signatures under the Law, including licensing of e-signature
services and
issuing digital certificates. Except for references to digital certificates
(which are normally
associated with PKI systems), the Law is technology neutral. In a departure
from best practice
in e-signature legislation globally, the Law does not contain a “party
autonomy�? provision
which would enable the parties to a particular electronic transaction to
establish a framework
as between themselves of how they would authenticate each other. Also, the only
“scope�?
provisions (i.e., a description of the types of transactions that the Law
applies to and what types
of activity are beyond its application) is the reference in article 14 of the
Law to civil,
commercial and administrative dealings.

The main legal instrument implementing the Law is the Decree. The Decree
sets forth
provisions regarding the establishment of so-called public and private key
infrastructure (PKI)
for purposes of authenticating the users of e-signatures and the content of
electronic

3
Both available at: http://www.itida.gov.eg/E-Signature_Regulations.asp
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 documents, including the role that ITIDA will play as the root certifying
authority (Root CA)
and in the regulating certificate service providers (CSPs). In that sense the
Decree is not
entirely technology neutral. While under the Law, there is no stated preference
for the kind of
legally recognizable e-signature, a PKI preference is emerging under the decree,
though it is
understood that use of PKI-based e-signatures will be mandatory. In principle this
might mean
that while other forms of electronic signature that otherwise meet the
requirements under the
Law, they might not be presumptively be granted legal functional equivalence to a
wet ink
signature on paper, requiring the party or parties to meet the burden of proof
that the electronic
signature was valid.

B. Institutional Arrangements

Under the Law and the Decree, ITIDA acts as the root certifying authority
(Root CA) for
issuing digital certificates in Egypt. ITIDA will ultimately determine the
validity of every
digital certificate in Egypt, and will certify “foreign�?-issued certificates as
well. ITIDA will
license other entities to issue digital certificates as Certificate Service
Providers (CSP), who in
turn will issue digital certificates to end users in the private sector. On the
public side, ITIDA
will license a Government Certificate Authority (Gov CA) to issue digital
certificates for
official use. Figure 1 shows the organization of the Root CA structure. A “trust
center�? will
be built around the Root CA that will operate around the clock, the physical
attributes of which
will ensure the highest degree of security for the operational integrity of
ITIDA’s activities as
Root CA.

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Figure 1

Source: ITIDA4

In this capacity ITIDA will be acting as the Root CA and will be

licensing other CSPs.
As part if its functions as Root CA, ITIDA will be operating a secure Root CA
Trust Center.
The Root CA Trust Center will be responsible for issuing certificates to CSPs,
issuing smart
cards, providing time stamping services and other matters related to the
provision of electronic
signatures. The Trust Center will be a secure psychical place within ITIDA
consisting of a
multiple layer, secure-entry facility, as well as layered security for access
to the Root CA’s
systems. Hardware and software for Key generation will not be linked to the
Root CA’s other,
Internet-related networked systems. The Root CA Trust Center will not issue
certificates
directly to end users.

ITIDA has entered into Memoranda of Understanding (MoUs) with Germany and
Korea.

4
http://www.itida.gov.eg/E-Signature.asp
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Figure 2

Source: ITIDA5

C. Expected uses of e-signatures in Egypt

It is expected that digital signatures will be used in a wide variety of

transactional
contexts ranging from B-2-C to C-2-G and G-2-G transactions. C-2-G transactions
range from
drivers licensing to tax payments and beyond.

[ITIDA to Expand on contemplated uses of PKI and expected delivery

mechanisms]

5
Ibid.
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 V. Benchmarking

This chapter evaluates different aspects of the e-signatures enabling

environment and
implementation in Austria, Brazil, Canada, Germany, Malaysia, Mauritius, Mexico,
Singapore,
South Africa, South Korea, Thailand and the United Kingdom as follows:

Enabling Environment issues:

 legal basis for use of PKI (institutional arrangement and scope of
application)
 institutional arrangements (operational and functional attributes),
role in
certification process
 security (i.e. robustness of user authentication; weak vs. strong e-
signature)
 “party autonomy�?, and recognized authentication alternatives
 interoperability – cross border recognition and “cross-certification�?

PKI Implementation Issues:

 applications for e-signatures PKI (for e-government processes)
 distribution of e-signatures (smart cards, soft tokens, “password�?,
etc.)
 cost of issuing certificates

The main lessons learned concerning each category and the relevance of these
lessons to
the situation in Egypt follow, and are supported with country examples. This
benchmarking
focuses on key issues of rolling out PKI-based e-signatures in Egypt.

A. Enabling Environment issues

A summary matrix of the benchmarking of the enabling environment is provided

as
Annex 1. The matrix shows, in tabula format, the findings for each country against
the
benchmarking criteria.

A theme cutting across the different enabling environment issues the

importance of
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 creating and publishing certificate practices and policies, a key element in
the non-legal part of
the enabling environment for PKI. This is especially true in case of Root CAs,
as will be the
situation in Egypt. These practice statements and policies can cover the legal
basis for the
activity, the institutions involved in PKI and their respective obligations and
responsibilities,
operational requirements, as well as security controls, for example.6

1. Legal basis for use of PKI (institutional arrangement and scope of

application)

With few exceptions (e.g., Australia), countries seeking to promote either

approach (e.g.
promoting the establishment of certificate issuers or accreditors) generally
set out the
requirements to become a certification authority (“CA�?) by statute or
regulation. Australia has
chosen to forego the legislative route and to initiate a policy approach known
as “Gatekeeper�? 7,
which provides the infrastructure in which government agencies can ensure the
authenticity,
integrity, and confidentiality of online activities. Any person or body that
receives
accreditation under Gatekeeper becomes a CA. It appears to date that a small
number of
agencies have received accreditation in Australia: eSign Australia Pty Ltd.,
The Australian
Taxation Office, Health eSignature Authority Pty Ltd.8 and Telstra Corporation
Limited.

As regards the scope of application for e signature legislation, although

a wide range of
areas can be subject to e-signatures, most countries do provide for exclusions.
For instance in
Austria, the following transactions are excluded from the applicability of the
e signature law:
inheritance laws, legal transactions requiring officials certification,
judicial or notarial
authentication; land or companies registration or guarantee declarations. A
similar exclusion is
provided for in the e signature law of Singapore (See Annex 1). In Thailand,
for example, the
law applies to “all civil and commercial transactions except those excluded by
a Royal Decree�?
thereby reserving to the authorities a wide discretion to determine the scope
of the law’s
applicability.

2. Institutional Arrangements

The role of institutions in the certification process can be two-fold. An

institution may act
6
See, e.g., Certification Practice Statement, Version 1.1, Korean Information
Security Agency, 2001.
See,also , PKI Assessment Guidelines, American Bar Association, Information
Security Committee,
Section of Science and Technology Law, 2003, for a general overview of policy
content and guidelines.
7
http://www.agimo.gov.au/infrastructure/gatekeeper
8
This organization is transitioning into Medicare Australia later in 2007.
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 as a certificate issuer or serve as an accreditation body for organizations
seeking to become
certificate issuers.

Two different accreditation methods exist, namely licensing and

voluntary accreditation.
While several U.S. states, Singapore and Malaysia have chosen to issue
licenses to certification
authorities, the United Kingdom, Germany, Ireland, South Africa and the
Canadian province of
Quebec have chosen a system of voluntary accreditation. An example of
voluntary
accreditation in the United Kingdom is tScheme9. The organization develops
sets of criteria
called Approval Profiles for commercially offered trust services. These
profiles permit service
providers - who can demonstrate that their services meet these sets of
criteria - to use the
tScheme approval mark. In order to obtain permission to use the mark, a trust
service provider
is assessed using the relevant profiles by an independent tScheme-recognized
assessing body.
Following independent certification of compliance with the tScheme criteria,
the trust service
is granted approval by tScheme Ltd, including the right to display the tScheme
mark.

The two systems described above (tScheme in the U.K. and Gatekeeper in
Australia) do
not differ fundamentally in their approaches and actually impose similar
criteria for those
seeking to become authentication service providers.

Institutions, as noted above, may issue certificates. In the United

States, the ACES10
Program was created to facilitate access to government services offered by
agencies through
use of information technologies, including on-line access to computers for
purposes of
reviewing, retrieving, providing, and exchanging information. One
organization, Operational
Research Consultants, is authorized to act as a shared service provider and to
provide digital
certificates to US government institutions. In Canada, Public Works and
Government Services
Canada operates a Certification Authority as a shared service provider to
federal government
departments and is seeking to extend its client base to provincial governments
as well.

Further complicating the description of the role of institutions in the

management of
digital certificates, is the fact that they may not issue certificates to end
users or accredit
certificate issuers but provide the “trust anchor�? for the underlying Public
Key Infrastructure
(“PKI�?).
9
http://www.tscheme.org/about/index.html
10
Access Certificates for Electronic Services
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 Large PKIs often have a hierarchical trust model. This means that a common
root Certificate
Authority (“CA�?) that signs the “signing�? certificates of CAs that issue
certificates to end
users. Using a rough manufacturing analogy, the Root CA provides the machinery
(signs the
“signing certificate�?) that permits wholesales to provide certificates to
retailers who in turn
provide it to customers. Customers trust the retailer because they know the
Root CA is backing
the “product�?.

A hierarchical trust model provides the “trust�? between different CA

systems subordinate
to the root and between different applications. An institution will be
identified to serve as the
policy authority for the PKI and operate the root CA. In controlling the
Certificate Policy that
governs the Root CA and by operating the Root CA itself, the institution
maintains control
over the PKI while allowing for distributed key and certificate management.

In India, one of the objectives of the Information Technology Act of

2000 11 is to promote
trust in electronic environments. The Act creates the office of the
“Controller of Certifying
Authorities�?, which has the responsibility of acting as a “Root�? Authority
to certify the
technologies and practices of all the Certifying Authorities licensed to issue
digital certificates.
It also licenses Certification Authorities and acts as a regulator to ensure
that legislative
requirements are satisfied. Similarly in Singapore and Malaysia, the Minister
appoints a
Controller of Certification Authorities with a supervisory and monitoring
role. In South
Africa, the Director General of the Department of Communications acts as an
Accreditation
Authority with a similar supervisory and monitoring role as the Comptroller in
Singapore.

In other jurisdictions, agencies may be provided with a more global

“role�? with respect to
the issuance and management of digital certificates. In Tunisia, the National
Digital
Certification Agency was created to:

 Secure the electronic transactions and exchanges;

 Cross-certify or mutually recognize foreign Certification Authorities;

11
Available online at:
http://unpan1.un.org/intradoc/groups/public/documents/APCITY/UNPAN010239.pdf See
section 18(b) for Root Certifying Authority role and section 20 for role as
National Repository of Digital Signature
Certificates.

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  Manage digital certificates;

 License digital certification services providers;

 Evaluating cryptographic tools;

 Provide security solutions based on digital certification for

networks and for Internet
and Intranet services; and

 Provide training in digital signature, encoding techniques and public

key
infrastructure.12

The approach in Mauritius is similar to that taken in Tunisia. Under

section 18 (z) of the
Information and Communication Technologies Act 200113, the ICT Authority is to
act as the
Controller of Certification Authorities (“CCA�?). The Controller of Certifying
Authorities as
the “Root�? Authority certifies the technologies, infrastructure and practices
of all the
Certification Authorities licensed to issue digital certificates.14

Interoperability with other PKIs in other domains (e.g. financial,

health) or in other
countries can be at root level. See the section on Interoperability below.

So-called “Bridge CA s�? provide facilitate one entity accepting

certificates issued by
another entity for a transaction by providing a connection between the PKI
infrastructures of
different institutions ensuring interoperability of those infrastructures and
establishment and
promotion of best practices and standardization.

While institutional aspects of the enabling environment are normally

associated with
formal, governmental organizations, private sector, industry led initiatives
can also play a role.
For example, the PKI Forum of Singapore15, an industry led initiative, founded
the Singapore
PKI Technology Support Center (SPTC) for testing of PKI.

3. Security of Digital Certificates

12
For further information, visit: http://www.certification.tn/index.php?id=95
13
Available at: http://www.gov.mu/portal/goc/ncb/file/ictact.pdf
14
 See http://www.icta.mu/it/elec_sig.htm
15
www.pkiforumsingapore.org.sg .
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 The level of assurance associated with them determines the security
associated with
certificates. CAs often issue certificates having different levels of
assurance or for different
forms of key generation The type of certificate to be used is often associated
with the purposes
for which the certificates are intended to be used. Similarly, one might view
the “strength�? of
signature is a function of the security associated with the certificate and
the authentication of
the certificate holder.

An important distinguishing characteristic between certificates is where

key generation
occurs and how it is stored (more on this in the next section). Another
important distinguishing
characteristic is the degree to which certificate holders are authenticated.
Less secure
certificates might have online authentication and browser key generation. More
secure
certificates might have in-person authentication with key generation occurring
in tokens. The
CA’s Certificate Policies are the documents that describe the degree of
security to be
associated with each level of assurance it offers with the certificates it
issues. Certificate
authorities often readily make their certificate policies available.

Canada’s federal model PKI certificate policies are available at:

Those used by Canada’s

http://www.tbs-sct.gc.ca/pki-icp/guidedocs/cert-policy/aboutCP_e.asp.
Financial Transactions and Reports Analysis Centre (FINTRAC) are available at:
http://www.fintrac.gc.ca/reporting--declaration/pki/CP_e.pdf

In the United States, the policy framework governing the public key
infrastructure (PKI)
component of the Federal Enterprise Architecture is available at:
http://www.cio.gov/ficc/documents/CommonPolicy.pdf. This policy framework
incorporates six
specific certificate policies: (i) a policy for users with software
cryptographic modules, (ii) a
policy for users with hardware cryptographic modules, (iii) a policy for
devices, (iv) a high
assurance user policy, (v) a user authentication policy, and (vi) a card
authentication policy.

Australia’s PKI Framework has three Digital Certificate categories –

Special, General
and High Assurance for Individuals and businesses – which are mapped to the
four levels of
risk in the Australian Government e-Authentication Framework.16 The
Certificate Policy for

16
The authentication framework can be found at
http://www.agimo.gov.au/infrastructure/authentication/agaf_b .
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 Businesses can be found at:

http://www.agimo.gov.au/__data/assets/file/53619/General_Business_Certificate_Polic
y_Specification.
rtf

Europe’s approach to digital certificates has been the most structured

of such initiatives.
The EU Signatures Directive17 was adopted by the European Parliament and the
Council in
December 1999 with all 25 EU Member States implementing the general principles
of the
Directive by 2006. The main objective of the Directive was to create a
Community framework
for the use of electronic signatures and ensuring a basic legal recognition of
electronic
signatures. The results have been mixed to date.18

There are three types of signatures recognized under the Directive.

 “electronic signature�?: a broadly defined concept, applicable to any

authentication of
information (e.g. a PIN, a name on an e-mail) as opposed to a person or
organization;

 “advanced electronic signature�?: principally digital signatures (issued

be “untrusted or
unknown�? CA issuing digital certificates�?\); and

 “qualified electronic signature�?: not explicitly recognized as such in

the Directive, this
is advanced electronic signature based on a qualified certificate,
created by a secure-
signature-creation device and meeting technical requirements described
in the Directive’s
three annexes (issued by “trusted CA issuing digital certificates�?).

In terms of the security of certificates, it is the qualified

signatures, based on qualified
certificates that offer signatures that are the most “acceptable�? in terms of
being linked to an
identity. The “qualification�? of the certificate goes to the quality of the
certificate policy
governing the authentication/registration of the certificate holder and the
secure protection of
the certificate (and keys) during the life of the certificate. The term
“qualified certificate�? is not
used outside of Europe but the concept of minimum standards to which the
issuer of the

17
Directive 1999/93/EC of the European Parliament and of the Council of 13
December 1999 on a
Community framework for electronic signatures, OJ L 13, 19.1.2000, p.12 .
18
See Report From The Commission To The European Parliament And The Council,
Report On The Operation Of
Directive 1999/93/Ec On A Community Framework For Electronic Signatures, March
2006.
available at:
http://ec.europa.eu/information_society/eeurope/i2010/docs/single_info_space/
com_electronic_signatures_report_en.
pdf

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 certificate must adhere is universally recognized. The “quality�? of the
certificate is linked to
the “security�? of the certificate and the practices of the CA.

It is worth noting here the recent conclusion of the UNCITRAL Working

Group on E-
commerce:

“PKI seems to be the authentication method of choice when strong

evidence of identity
and high legal certainty of the electronic signature is required. The use
of PKI-enabled
smart cards and the integration of digital certificate functions into
application software,
have made the use of this method less complicated for users. However, it
is generally
acknowledged that PKI is not required for all applications and that the
choice of
authentication method should be made on the basis of its suitability for
the purposes for
which it would be used.�?19

In South Africa, the law provides for the presumption in favour of

“advanced electronic
signatures’. It states that “Where the signature of a person is required in
law and such law does
not specify the type of signature, that requirement in relation to a data
message is met only if
an advanced electronic signature is used.�?20

4. “Party Autonomy�?, and Recognized Authentication Alternatives

Generally, “party autonomy�? is a common feature in most e-commerce

legislation.
Austria, Germany and Singapore, for example, specifically provide that use of e-
signatures is
voluntary.21 In countries where party autonomy is not explicit, the legislation
contains provisions
from which one could discern that use of e-signatures would be voluntary. For
instance, in
Thailand, the Act provides that the requirements of the Act “[do] not limit that
there is no other
way to prove the reliability of an e signature.�?22 In South Africa, provisions of
the law relating to
e signatures fall under a part of the law which is mandatory and, therefore, e-
signature provisions
cannot be varied by the parties.23

19
UNCITRAL Future Work, at para. 13(c), p. 9.
20
Section 13(1) of the Electronic Communications and Transactions Act, 2002.
21
Section I §1(2) of Federal Electronic Signature Law of Austria; Section §1(2) of
German Electronic
Signatures Law and Section 5 of Electronic Transactions Act of Singapore;
Section
22
Section 26 of Thailand’s Electronic Transactions Act (2001)
23
Part 1 of Chapter III of Electronic Communications and Transactions Act; see
also D. Campbell, E
Commerce and the Law of Electronic Signatures, p. 567
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 5. Interoperability

Generally within one PKI domain, a document that is associated with a

digital certificate
(e.g. has been digitally signed) is validated by the CA that both the sender
and recipient share.
Interoperability is raised as an issue when the sender and recipient and in
different domains and
the recipient must rely upon his/her CA to establish trust with the other
domain.

This has both technical and non-technical aspects. Technically, PKI

applications must
conform to technical standards in order to be able to access accurate
directories which indicate
the purpose, quality and status of digital certificate used to sign the
document. The non-
technical aspect requires the establishment of a relationship between the
domains or Cas. This
means mutual recognition and a technical connection. Technically, this means
there are four
options for conveying recognition of a CA: hierarchical CA certificates,
cross-certificates,
certificate trust lists and a bridge CA. This paper does not propose to
examine in detail these
different approaches but notes them to indicate the interoperability approach
taken by different
governments.

When discussing PKI Interoperability, there is a preference towards the

bridge CA model
both in Europe (see below) and North America.24 The principle objective of any
bridge CA is
to serve as a “stable�? third party to co-ordinate and promote PKI
interoperability by whatever
means necessary. Individual governments, accreditation agencies and CAs do not
have
sufficient motive, skills or resources to deliver and maintain
interoperability.

Complicating matters is that there is there is no universal model to

adopt or recommend
for CAs within a domain. There is some doubt that any country starting a PKI
should start with
a “bridge model�?. Experience to date in the US and Canada would seem to
suggest that while
a bridge system between CAs eventually is needed, governments start by using a
single
certificate authority within government as a shared service provider (as
opposed to different
institutions having different CAs and trying to connect them together).
24
Slightly dated but I believe still a valid conclusion. See Stillson K D, Public
Key Infrastructure
Interoperability: Tools and Concepts, The Telecommunications Review 2002
http://www.noblis.org/Publications/Stillson_07.pdf
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 As the term suggests, PKI is about infrastructure – an enabling platform
to permit the
development of secure e-government or e-commerce. It is not technology to
easily deploy. The
establishment of one or more CAs is a challenging task given the complexity of
the technology
and the need to support and/or develop applications that utilize the
technology.

It is arguable that the cost of deploying a CA (and associated

certificate management)
together with the need for trained personnel and interoperability (in
connecting two or more
Cas) should lead to the deferment of a central bridge CA model and reliance on
one CA to
issue certificates for a number of institutions using a shared/common service
provider model.

There does not appear to be a clear consensus on the best

interoperability model below
the bridge CA level. In the Canada and the United States, at the federal
level, there are bridge
Cas. When a PKI cross-certifies with a bridge CA, a Relying Party can trust
that PKI’s digital
certificates at the Level(s) of Assurance asserted by those certificates. A
list of organizations
that have cross-certified with the US Bridge CA may be found in Annex B.

It is important to note that the US Federal Bridge CA accepts the

Certificate Policies as
submitted by the CAs – an approach that requires Relying Parties to make their
own trust
decisions as to whether or not to accept the digital certificate.

In Europe, officials of institutions participating in networks of the

inelegantly titled
Interoperable Delivery of pan-European eGovernment Services to Public
Administrations,
Businesses and Citizens (“IDABC�?) use digital certificates issued by the
IDABC PKI. The EU
tried (or is trying) a different approach in using a bridge CA: establishing
the necessary trust
relationships through the distribution of certificate trust lists, digitally
signed by the bridge CA.
A report on trust list usage, together with the architecture and a pilot
program, were developed
as of 2004.25

25
 See Bridge/Gateway Certification Authority Page at:
http://europa.eu.int/idabc/en/document/2318
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 The following summary table provides some international examples of
interoperability.26

Root CA / Cross Cross

Bridge CA Certificate Trust
Hierarchy Certification Recognition
List
(Mesh)

Brief An organised Cas certify each Cas/PKI A

central bridge A list of trusted
Description chain of Cas, other as peers domains agree CA
manages CAs is distributed
run from the top to recognise
interoperability
down. each other’s
between all other
certificates Cas

Role Technical Technical Political and

Technical Technical
mechanism to mechanism to contractual
mechanism to mechanism to
convey convey process of convey
convey
recognition. recognition. establishing
recognition. May recognition.
May also have recognition. also
have role in
role in
managing
establishing
recognition.
recognition.

Working Global – Asia – PAA US

Federal EU – Government
examples Identrus Bridge
Bridge
Australia –
Germany – Gatekeeper / EU –
Commercial
RegTP Angus Bridge

Agreement Tight Only between Political co-

Consensus of Only useful if
required agreement from CAs as needed operation CAs to
use publisher already
the beginning bridge
has authority

Technical Yes – fully Yes – but may PKIs remain Bridge

can play a Requires another
interoperability interoperable require separate at role
in managing mechanism to
– design stage significant technical level
interoperability establish
modifications
recognition (eg

Cross

Recognition)

Technical Yes – fully Yes – fully Requires use of

Partial technical Yes – fully
interoperability interoperable interoperable other tools (eg
interoperability interoperable
– real time Trust Lists) to only –
stronger if
operation achieve used
with other
technical tools
(eg Trust
interoperability Lists)

Costs Low – simple, High – each Low-Medium – Medium

– bridge Low, but varies
easy system pair of CAs co-ordinating CA has
with modes of use
must go body must
significant
through enforce rules
workload
expensive and audit
process to participants
cross-certify

Scalability Medium – short Low – full mesh Medium – no

Medium-High – High – simple,

26
This table is found in at:
http://www.galexia.com/public/research/articles/research_articles-
art32.html#Heading96
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 2
and certain has n pairs, technical
limiting factor is direct trust
certification certification barriers, but bridge
workload
paths back to paths may be challenging
trusted root long administrative
co-ordination

Security risks High – single Low – single Low – depending Medium

– breach Medium –
breach of root breach may on level of of
bridge brings depending on
brings down have no effect technical down
network, implementation,
network, on others, or integration, but
participants may be lag
subordinate may fragment probably no can
still operate between security
CAs must be network effect on network on
their own breach and list
re-certified
update

Most countries provide in their laws for cross-certification and cross

border recognition of
certificates, even if subject to certain conditions being met. The laws in
Austria and Germany
have guidelines on the recognition of foreign certificates one of which is
that such certificates
must meet the requirements for the issuance of certificates under the EU
Directive. 27 This is
mainly the case with certificates originating from non EU states. Certificates
from EU member
states are considered equivalent to domestic (qualified) e signatures. In
other countries, foreign
certificates are treated on an ad hoc, case–by-case basis. In South Africa and
Singapore, the
power is reserved for the Minister responsible to recognize foreign CAs from
particular
countries through regulations published in the Gazette. Surprisingly in
Mauritius, the law is
silent on either cross-border or any provisions on interoperability.

B. PKI Implementation Issues

1. Applications

Most digital signature applications are generally integrated with

business applications.
Often the digital certificate is not obvious and is otherwise “below the
surface�? and not visible
to the user. Because of this, the digital certificate is often a “general
purpose�? certificate,
which is used to identify the user in a relatively wide range of transaction
types. The epass in
Canada serves as an example, where the CA issues a certificate to the user but
the government
institution does the mapping between the digital certificate and identity.

Five years ago, web-based applications were the most popular PKI
applications in the
27
Section 24 of Austria’s Federal Electronic Signature Law; and Section 23 of
German’s Law on
Framework Conditions for Electronic Signatures
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 market followed by server certificate authentication. Organizations preferred key
pair solutions
(server certificates) compared to hardware type solutions (tokens) mainly due to
its ease of
implementation. Now, with two-factor authentication becoming more “mainstream�?,
the use of
a physical item (e.g. tokens, smart cards, grid card) may increase.

Most digital certificates issued today are used in a relatively limited

range of applications.
A lot of the digital certificate applications are e-government related. Generally
there is a dearth
of applications available that will use digital certificates.

Software often can select and invoke the appropriate certificate

automatically, without
user intervention. This is beneficial in making the user’s experience of digital
certificates (and
the associated key management) relatively painless and seamless for the user.
However, a
serious question to consider is how well can the technology be implemented into
existing
information technology infrastructures. The “plus�? side of this is that the use
of third party PKI
service providers becomes a more attractive option for organizations and
government
institutions.

The applications that can use digital certificates vary but can be broadly
placed in a series
of categories

 Authentication, through the verified issuance of a digital certificate.

 Verification of integrity, through the use of valid digital signature keys

contained in a
digital certificate;

 Authorization, through the use of a valid digital signature keys contained

in a digital
certificate; and

 Confidentiality, through the use of a valid encryption keys contained in a

digital
certificate.

Authentication may consist of confirming the identity of a natural person or

a machine or
the source of a document or code. Verification of integrity may apply to the
contents of an
electronic document or to the executable code.

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 Digital signatures may serve as the electronic equivalent of “wet�? or
“paper-based�?
signatures. In a large number of jurisdictions, the equivalency of such
signatures has been
confirmed in law. For example, in Austria, the use of a secure electronic
signature meets the
legal requirements for a hand-written signature under the Federal Elextronic
Signature Law.28
The German law provides that use of a qualified e-signature meets the legal
requirement for a
hand-written signature.29 A requirement in law that a document or information
must be in
writing is met, in South Africa, if the document or information is “in the
form of a data
message�?.30 A similar provision is contained in the Mauritius e signature
law.31

Illustrations of how digital certificates are used can be seen in a

number of different
countries.

(a) Finland

In Finland, the Population Register Centre and, a mobile telephone

provider, TeliaSonera
Finland, are issuing the “State Citizen Certificate�? to enable secure mobile
communications
and commerce. The Citizen Certificate is included in SIM cards, which permit
mobile phone
users to authenticate themselves for both public and private sector services.
The Citizen
Certificate card was made available in January 2005.32

Finnish government employees are being issued “Chip ID cards�?. The

photo ID cards
contain a digital certificate, which permits authentication of network users
and their usage
rights; encryption of email and documents; and a digital signature. Uses
include access control
systems, teleworking, passage control and physical identification33

More specific applications include:

28
Section 2 §4(1)
29
See D. Campbell E Commerce and the Law of Electronic Signatures, p. 240
30
Section 12 of Electronic Communications and Transactions Act (2002)
31
 Sections 5 and 6 of the Electronic Transactions Act (2000) of Mauritius.
32
See News report at: http://e.finland.fi/netcomm/news/showarticle.asp?
intNWSAID=30340
33
E-Government in Finland 2007. Available at:
http://ec.europa.eu/idabc/servlets/Doc?id=28744
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  Online change of address34

 Electronic Birth Registration35

 Online tax filing36

(b) Canada

The federal government created and made available its “epass�? in

September 2002 to
further its e-government objectives. An epass is a “zero footprint�? digital
certificate issued and
downloaded to a client’s computer each time a secure Internet transaction is
initiated, and
remains downloaded only during that transaction. The certificate, once
validated by the
government department responsible for the program, ensures that the client
will be
automatically recognized during future transactions with the department.

An epass is used with a program that requires both the Government of

Canada and the
user to be authenticated. Users are allowed to have a different epass for each
epass-enabled
Service.

The first provider of epass-enabled service was the Canada Revenue Agency
(“CRA�?).
As of March 2007, fifty-nine of sixty-five programs on-line across twenty-two
Canadian
federal government departments are epass-enabled. These include:

 CRA’s MyAccount and My BusinessAccount;

 Service Canada’s Record of Employment; and

 Foreign Affairs Passport Online

Some statistics of interest include:

34
See:
http://www.vaestorekisterikeskus.fi/vrk/home.nsf/maindocuments/
a092a36e225eadfec2256c93003bae20?opendocu
ment
35
See http://e.finland.fi/netcomm/news/showarticle.asp?intNWSAID=44510
36
 See https://www.cosic.esat.kuleuven.be/modinis-idm/twiki/bin/view.cgi/Main/
FinnishProfile
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  Over 2.4 million epasses were issued as of February 2007.

 Over 50,000 businesses use the online Record of Employment service

 Over 6 million logons by business clients in 2006.37

(c) United States

According to a December 2003 study prepared by the Office of Management

and Budget
in the United States38 20 of the 24 agencies reported that they were
undertaking a total of 89
PKI initiatives. These initiatives represented a significant investment,
estimated at about $1
billion. The report identified a number of challenges for the implementation
of PKI-enabled
applications within the American government.39

(d) European Union

In Europe, given the existence of the EU Signatures Directive and

issuers of qualified
certificates, a number of e-government applications are used in conjunction
with “electronic ID
cards�?. In providing on-line access to government services, these cards have
three main
functionalities: identification, authentication and signing. In Belgium, for
example,
approximately 1.3 million electronic ID cards have already been activated.40

Overall, the “market�? for digital certificates and the associated

signatures has been slow
to develop. Part of the problem is technical (the complexity of PKI systems;
the lack of
interoperability between different domains); part is simply the demand for
trusted third parties
(the Cas) authenticating an identity for general purposes. Application
“owners�? have little
reason to develop multi-application uses for digital certificates

Most uses of digital certificates occur in “closed�? PKI systems where

all the parties are

37
See “Secure Channel and e-business Standards�?. Presentation by Bob Sunday,
Office of Chief Information Officer,
Government of Canada, available at: www.isacc.ca/isacc/_doc/Book21-2007/ISACC-07-
37304.ppt
38
While this OMB report is somewhat dated, an extensive literature search provided
this as the only document
discussing US e-government initiatives that use PKI.
39
See Highlights document available at:
http://www.pubklaw.com/ecomm/d04157high.pdf. The full report
is available at: http://www.gao.gov/new.items/d04157.pdf
40
See “Electronic Identity Being Consciously Promoted in Europe and Around the
World�? available at:
http://e.finland.fi/netcomm/news/showarticle.asp?intNWSAID=43382

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 somehow known to each other (e.g. the issuer is the institution with whom the
certificate
holder is or will become a client). From a privacy perspective, this is not a
bad thing but it
means that digital certificates are often used for only one application. In
Canada, the federal
government’s epass service is based on the CA not knowing the identity of the
certificate
holder.

(e) Asia

In Asia, the Asia PKI Forum is an organization established to promote

PKI
interoperability in the Asia/Oceania Region. Membership consists of the Macao
Post and PKI
Forums from Korea, China, Japan, Chinese Taipei, Singapore, Hong Kong and
Thailand.

The Forum divides itself into a series of working groups to address

technical and policy
issues.

 Legal Infrastructure Working Group issues an annual report concerning

cross-border e-
commerce;

 Business Case/Applications Working Group

addresses issues concerning the
development of an international e-business infrastructure through Asia
PKI Forum;

 Interoperability Working Group addresses PKI interoperability issues;

 World Wide Collaboration Working Group facilitates information sharing

and
collaboration concerning PKI as well as ICT security between the Forum
and other
organizations

In 2005, the Business Case/Applications Working Group issued an “Asia PKI

Application Case Book�?, which highlights the various business models in Asia
using PKI
technology. At that time, and without significant changes since then, the
technology is mainly
used for online authentication in e-government and e-banking contexts. The
report is available
at: http://www.asia-pkiforum.org/web/Column.asp?ColumnId=21 under the heading
“Resources�?.41

An illustration of the pace of application deployment can be seen in this

quote from the
report on Japan:
41
Given the difficulty in locating the document, a copy will be provided to you
under separate cover.
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 “However, while the PKI utilization in the B2G field is moving forward, PKI
utilization for e-commerce in the fields of B2B and B2C is not making as
much
progressing as initially expected. Though it is true that about 20 private
businesses have adopted the designated certification services that are
described by the Electronic Signature Law and have issued Public Key
Certificates, the majority of these certificates are not used for e-commerce
between private companies. Rather, they are mainly used in the B2G field
for electronic government services on the local and national level.�?

In Korea, the outlook is expressed more positively:

“Internet Banking
All banks deployed licensed certificate authentication system. If a customer
has to
transfer his money online, the customer must sign digital signature using
his
licensed certificate. Some banks enhance the level of control by blocking to
see
the transaction of an account if they haven’t a certificate.

Online Stock trading

All securities deployed licensed certificate authentication system. If a
customer has to trade his stock or transfer money online, the customer has
to
log-in by submitting digital signature using his licensed certificate. A
customer
can submit digital signature for transaction each time.

E-Government
The government services web sites for civil petition, many types of
certificate
issuance, notification of internal work process, etc. With licensed
certificate,
people submit their digital signatures when it is needed and access related
information, get certificates by printing, and request civil petition.

E-Commerce
When they use credit card on the Internet shopping mall site, they have to
submit digital signature if the total price of the product exceed 300,000
Korean Won. It is now applied to major two credit card companies, but
supposed to apply to every credit card company from October 2005. It is
expected to
block illegal usage of credit cards.�?

Specific examples of applications can be seen in:

 Korea: Education: Confidentiality and Integrity for School/Student

Information

 Korea: Education: Parental Approval Via Digital Signature

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  Korea : E-Commerce : Digital Content Authentication

 Japan: Healthcare: Medical And Healthcare Network

 Japan: E-Commerce: Electronic Account Receivables For Small-Medium

Enterprises�?

 Chinese Taipei: E-Government: PKI Applications In E-Government

(f) Africa

Tunisia has established a very modern approach to the use of digital

certificates,
ocusing on e-government, e-commerce and e-banking applications to date.
Applications
include e-filing for taxes42; online payment accounts43; server certificates
for merchant web
sites44 and on-line banking45. In South Africa, the law provides for the
acceptance of filing and
issuing of documents by public institutions. However, the law further sets out
various
conditions (specific to the use of e signatures in public bodies) within which
this can be done to
ensure security and confidentiality.46

The emphasis in deploying any PKI or establishing a CA is to ensure that

the emphasis is
on the business application and not on the PKI technology itself. A digital
certificate is a means
to an end – secure online transactions/communication. This means that the
identification of the
certificate holder has to be reasonable in the context of the application for
which its use is
sought. This in turn argues for a reasonable “mapping�? of application to
level of assurance in
the certificate. A high assurance certificate is not needed for a low risk
transaction in a closed
PKI environment. As a result, one area to consider is how to facilitate
enrolment of certificate
holders.

2. Distribution of Certificates

A digital certificate is simply an electronic file, digitally signed by a

CA that contains
certain elements or “values�? such as the certificate name and usage,
certificate holder
information, the public key itself, an expiration date, and the name of the CA
that generated the

42
See http://www.certification.tn/index.php?id=149
43
See http://www.certification.tn/index.php?id=139
44
See http://www.certification.tn/index.php?id=140
45
See http://www.certification.tn/index.php?id=128
46
See section 28 of South Africa’s Electronic Communications and Transactioons
Act, 2002.
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 certificate.

It is perhaps obvious, but the security provided by digital certificates is

only as good as
the security provided for the storage and use of the private keys. Digital
certificates can be
stored on the user’s computer, in software modules, or on hardware devices like
smart cards or
other hardware. The choices then are essentially distributing digital certificates
in either
software or hardware form.

Certificates stored on a computer hard drive are the least expensive means
of storing a
certificate but also the least secure. Essentially, a browser generates the
private and public
keys. The certificates and private keys are then stored in PIN-protected,
encrypted files on hard
drives. The browser performs functions such as encryption/decryption and digitally
signing
electronic documents using those certificates and private keys.

Smart cards/tokens/devices contain a microprocessor and memory and provide

the most
secure solution because keys are generated on the card or device with the
certificates and
private keys are stored in an encrypted file on the card, token, or device. The
encryption/decryption and digital signing functions are performed on the card or
device. As a
result, the private keys are never exposed outside the device.

These devices come in different forms including:

 Smart cards with card reader that generally connect to computers

through a
Universal Serial Bus (USB) port or through a PCMCIA card slot;

 USB token that plug directly into a Universal Serial Bus (USB);

 Fingerprint devices; and

 Embedded-in-the-computer security chips.

The eventual choice in the distribution of digital certificates is a function

of security as
well as the application for which the certificate is required for encryption or
signature
purposes. Digital certificates and their associated keys are generally used by web
browsers and
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 e-mail clients for user authentication and/or digital signatures. This means
they will need to be
stored so that they can be easily retrieved by the user for these functions.
If the application (or
perhaps more accurately the information being accessed or used by the
application) is more
sensitive then additional security requirements may dictate the use of
“devices�? to hold the
certificate (e.g. smart card or token). It is important to emphasize that the
security is not really
for the certificate but the keys associated with them.

Apart from anecdotal examples already included in this report,

little hard
comparative data were discovered about either the numbers of certificates
issues or the volume
of electronic transactions using such certificates. 47 Information regarding
the operations of
certification authorities or certification service providers, including
details of the number of
certificates issued (by whom when and how distributed), the transaction volume
and the costs
for issuing certificates is limited on public websites of the countries
surveyed. As a result, we
have not been able to establish any comparative pattern of the costs or
distribution mechanism
or transaction volume among these countries. In Austria, for example, a number
of accredited
Certificate Service Providers (“CSP�?) (2) supervise the activities, in turn,
of a number of other
CSPs (6) who have issued thousands of Qualified Certificates (“QC�?). In
Germany, some 23
accredited CSPs have some tens of thousands of digital certificates. And in
Malaysia, for
example, some 22 million smart cards using a PKI system have been issued, for
use in more
than a dozen applications.

3. Cost of Issuing Certificates

The development of a system to provide digital certificates can be

easily characterized as
an “infrastructure�? cost. Calculating any return on investment (“ROI�?) for
digital certificates
alone is difficult.48 Any ROI often has to be linked to the application(s)
that the digital
certificate is intended to support and how the certificate assists in the
shift for the current
business process to an electronic process or a more secure electronic process.
Information on

47
 The figures provided here are drawn from data available at the public websites
in these countries.
48
For an interesting discussion on the subject of “calculating�? PKI ROI, see,
e.g., “Guidelines on how to determine
Return on Investment in PKI�?, available at:
http://www.oasis-pki.org/whitepaper/roi.pdf published by eh OASIS PKI
Group (OASIS Paper).

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 the pricing of certificates is often not readily available.49 Usually, in
terms of cost, the fixed
and variable cost of producing certificate no. 1 is the total cost of
establishing the Certification
Authority issuing the certificate. The marginal cost of producing certificate
no. 2 is zero (this
leaves aside any licensing fees associated with certificate production).

It is somewhat axiomatic to suggest that the higher the trust to be

placed in a digital
certificate, the higher the cost of the certificate. The cost of managing a
certificate is the global
cost of producing the certificate, registering the holder of the certificate
and then maintaining
the certificate throughout its lifecycle, which may include “helpdesk�?
support.

The OASIS Paper describes the various costs according to a “digital

certificate supply
chain�? (see figure 3), and breaks down costs according to each element in the
chain.

Figure 3

End
user
Registration
RA
CA
Certificates
Key

Media

Application
Adapted from
OASIS PKI White Paper

49
An illustration of pricing, the cost of obtaining identity and encryption
certificates under the ACES program in the
United States from one service provider, and examples of pricing for certificates
issued by the Washington State
Certification Authority are provided in Annex 3.
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 Four types of cost can be identified and need to be estimated to determine the
Total Cost of Ownership
for a PKI system:

A. Fixed Establishment Costs

B. Variable Establishment Costs
C. Fixed Annual Costs
D. Variable Annual Costs

Application related - All costs associated with PKI enablement of the

Application, including
planning and designing, ‘shopping around’ for a CA solution, acquiring any
necessary PKI toolkits
and ‘glueware’, and integrating PKI components with the application. In supply
chain parlance, the
Application is the eventual ‘consumer’ of certificates, and sits at the end of
the supply chain.

End user related - All costs associated with supporting end users, including
help desk, education, and
the marketing efforts frequently undertaken to promote the benefits of PKI.
Note that some costs are
borne directly by the user; for example, the user may need to spend time and
money presenting in
person to a Registration Authority (RA).

Certificates - The cost of certificates themselves. Outsourced CA service

providers and CA software
vendors usually charge a fee per certificate, which can be paid by application
scheme operators on
behalf of the users (and possibly passed on) or paid directly by the users
themselves.

RA - Costs associated with front-end registration. Internal enterprise RAs

operated for example by an
organization’s HR or customer service department might utilise regular office
staff and
accommodation, with little or no incremental cost. A bureau style third party
RA on the other hand,
providing general purpose identity certificates may have significant set-up,
infrastructure and staffing
costs. Third party RAs may have to make provision (or purchase insurance) to
cover potential liability
for errors and omissions.

CA - Costs associated with the backend Certification Authority operation.

Investment in security,
cryptographic systems, infrastructure, personnel, facilities and compliance
related activities will be
required in line with the risk profile of the PKI’s business application, and
the scale of the user
population. Enterprise CAs supporting internal applications might be
implemented using commodity
software products and operated within the organization’s IT shop. On the other
hand, a commercial
third party CA could require purpose built facilities, site redundancy, and
major independent audits, as
well as provision or insurance to cover potential liabilities incurred by the
CA operation.
 Key media - Costs of the media in which end user private keys are conveyed.
Can be close to zero for
simple soft certificates, or can entail license fees for roaming soft
certificate solutions. Additional
hardware expenses might be associated with certain media like smartcards where
readers may be
required.

Box 150

It is important to note that how one approaches the subject of

verification of identity

50
See, OASIS Paper,
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 will influence cost/pricing of certificates. As an example, the issuance of
certificates through
the epass program in Canada is done electronically; the verification of
identity is done online
through the use of shared secrets between the institution and the client
seeking to register a
digital certificate with that institution. This is a lower cost exercise than
if the client had to
present him/herself to an individual and provide tangible proof of identity.

Pricing and “cost�? determinations have many variables associated with

them and there
is no simple answer without detailed analyses of each of the variables in each
situation.
Additionally, because of the distributed nature of the cost of using PKI
across platforms and
for different purposes, even CA operators may not accurately know the overall
cost of the PKI.

In another example, the U.K. Government initiated a biometric-based

national ID card
program.51 The program was criticized both on the basis of too-low cost
estimates and
questionable technological assumptions of using biometrics. Regarding cost, an
independent
evaluation estimated that costs would be more than double Government
estimates. On
technical grounds, the use of biometrics was criticized as being unproven
technology, and the
reliance on a single database was criticized as too risky for the protection
of personal data. An
ancillary lesson learned from the U.K. experience is the importance of clearly
identifying the
purpose for which an electronic authentication system is to be used.

51
See, Eric Guizzo, “Britain’s Identity Crisis: Proposed biometric ID cards won’t
prevent fraud or terrorism�?, IEEE
Spectrum, January 2006.
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 VI. Recommendations for strengthening Egypt’s e-signature and
PKI enabling environment

The following findings and recommendations are intended to build on the

foundation for
PKI provided in Law and the Decree. In that sense they are aimed at enhancing the
trust and
confidence of users in the system in order to encourage use. They are also aimed
at helping to
identify where in the “certificate supply chain�? costs may be incurred, and to
isolate and reduce
downstream costs (actual and hidden costs).

A. As Root CA, ITIDA should develop certificate standards policies

applicable to Egypt, and can use its existing relationships with is MoU
partners in this regard.
One key element in the non-legal part of the enabling environment for PKI,
especially in
cases of Root CAs, is the existence and publication of a Certification Practice
Statement and
Policy that will govern the issuing and use of digital certificates. These
practice statements and
policies will cover the legal basis for the activity, the institutions involved in
PKI and their
respective obligations and responsibilities, operational requirements, as well as
security
controls, for example.

B. Measures to limit the liability of ITIDA as Root CA

Since ITIDA will be acting as Root CA in Egypt, in the absence of other
constitutional,
administrative or statutory protections, ITIDA should consider the manner in which
liability
will be apportioned between ITIDA, as Root CA, and users for erroneous
certificates, forged
signatures, certificates issued on false pretences, or errors in certificate
repository or CRL, for
example.

C. Clarify which electronic transactions will be subject to PKI

Currently, under the Law and the Decree, it is envisaged that there will be
a hierarchy of
electronic transactions. The Decree, for example, provides for electronic
signatures (which are
the equivalent of “strong�? signatures, the underlying transaction of which will
presumably be
subject to PKI) and electronic documents and writing (which are the equivalent of
“weak�?
signatures). Both are given legal effect under the Law and Decree. However, by
clarifying

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 which kinds of electronic transaction activities ITIDA expects will be subject
to PKI, ITIDA
can also better understand the cost and benefit structure of implementation of
PKI in Egypt. In
this regard it is understood that a key element of this will be the awareness
raising campaign,
which is the subject of the next phase of the World Bank RTA with ITIDA. This
campaign
should also foster trust and confidence and enhance greater use of the systems
made available
under the PKI regime.

D. Training for lawyers and judges on e-signatures issues

Another part of the awareness–raising campaign, and an essential part of
enabling
environment will be training of lawyers and judges in the different policy,
legal as well as
technical aspects of PKI.

E. Introducing alternative dispute resolution processes for e-signature

matters
Related to the foregoing issues of trust, confidence and awareness, and
because of the
unique issues involved in the use and application of PKI in certain electronic
transactions, it
will be beneficial to ensure the speed and certainty with which disputes
related to PKI are
resolved.

F. International Considerations
The United Nations General Assembly recently approved the opening for
signature of the
UNCITRAL Convention on Electronic Contracting (Convention).52 The Convention
applies to
cross border e-commerce activity, and therefore falls outside the focus of
this report, insofar as
the scope for the report deals with use of e-signatures within Egypt. However,
the Convention
raises a least one interesting issue with respect to the Law in Egypt. The
Convention contains
a “party autonomy�? provision that permits the parties to a transaction (or a
series of
transactions) to determine their own protocols – as between the parties – that
will apply in
terms of authentication. The Law only provides that foreign certificates
(i.e., PKI-based e-
signatures) can be recognized in Egypt. However, as noted in 4.A, above, the
Law does not
have a party autonomy provision. Therefore, in terms of cross-border
authentication, foreign

52
United Nations Convention on the Use of Electronic Communications in
International Contracts,
adopted by the General Assembly on 23 November 2005, available at:
http://www.uncitral.org/uncitral/en/uncitral_texts/electronic_commerce/
2005Convention.html
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 parties not relying on PKI-based authentication cannot be assured that their
electronic contract
will be automatically granted legal validity. It does not necessarily mean that
the contract
would be voided, but the burden of proof would shift to the party claiming
validity of the e-
signature. Finally, if Egypt were to ratify this Convention, it may need to do so
on the basis of
an exception to the Convention’s party autonomy provisions.

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 VII. Glossary

“Business to Consumer�? – refers to a commercial

electronic
B-2-C transaction between a natural person and an economic
enterprise

Bridge CA

C-2-G “Citizen to Government�? – refers to a non-commercial or

official electronic transaction between a natural person
and a
governmental organization

Certificate

CRL

“Government to Government�? – refers to an electronic

G-2-G transaction between two governmental organizations

(1) The key of a signature key pair used to create a

digital
Private Key signature.
(2) The key of an encryption key pair that is used to
decrypt
confidential information. In both cases, this key must be
kept
secret.
The key of a signature key pair used to validate a digital
signature.
Public Key
The key of an encryption key pair that is used to encrypt
confidential information. In both cases, this key is made
publicly available normally in the form of a digital
certificate.

Public Key A set of policies, processes, server platforms, software

and
Infrastructure (PKI) workstations used for the purpose of administering
certificates
and public-private key pairs, including the ability to
issue,
maintain, and revoke public key certificates.

Root CA In a hierarchical PKI, the CA whose public key serves as

the
most
trusted datum (i.e., the beginning of trust paths) for a
security

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 domain.

X.509 In cryptography, X.509 is an ITU-T standard for

PKI. X.509
specifies, amongst other things, standard formats
for public key
certificates and a certification path validation
algorithm. 53

53
See: http://en.wikipedia.org/wiki/X.509

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 VIII. Annexes

Annex 1 – Country Benchmarking Matrix

Annex 2 – Brazil – Examples of Digital Certificates

Annex 3 – Examples of Cost Structures

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 IX. Bibliography

Campbell, Dennis, (2005), “E-Commerce and the Law of Digital Signatures�?

Certification Practice Statement, Version 1.1, 2001, Korean Information Security
Agency,
Dekker, Cliffe, “E Commerce in South Africa�?,
available at:
http://www.cliffedekker.com/literature/invest/ecommerce.htm
Diodati, Mark and Blum, Dan, “Reference Architecture Technical Position, Public Key
Infrastructure�?, The Burton Group 2007,
available at:
http//www.burtongroup.com/guests/content/dss/testdrive/techpositions.asp
Dumortier, Jose et al, “The Legal and Market Aspects of Electronic Signatures�?
(the “EU
Report�?).
Fischer, Georges, “E –Commerce Law in Brazil�?, available at: http://www.connect-
world.com/Articles/old_articles/10E-Commerce.html
Guizzo, Eric, January 2006 “Britain’s Identity Crisis:Proposed biometric ID cards
won’t prevent
fraud or terrorism�?, IEEE Spectrum, , available at:
http://www.oasis-
pki.org/whitepaper/roi.pdf
Koanantakool, Thaweesak, “Electronic Commerce Development in Thailand’ available
at:
http://www.nectec.or.th/users/htk/e-commerce/intro.html
Lodder, Arno and Kaspersen, Henrik, ed (2002), “E-Directives: Guide to European
Union Law
on E-Commerce�?
Lweis, Jamie and Blum, Dan, 1999, “Public Key Infrastructure: Architecture and
Concepts�?, The
Burton Group,
Mazeo, Mirella, “Digital Signatures and European Laws�? also
available at:
http://www.securityfocus.com/infocus/1756
OECD Recommendation on OECD Guidance for Electronic Authentication, available at:
www.oecd.org/sti/security-privacy
PKI Assessment Guidelines, American Bar Association, Information Security
Committee,
Section of Science and Technology Law, 2003
Possible future work on electronic commerce Comprehensive reference document on
elements
required to establish a favorable legal framework for electronic commerce:
sample chapter on
international use of electronic authentication and signature methods, UNICTRAL,
ACN.9/630/Add.3, available
at:
http://daccessdds.un.org/doc/UNDOC/GEN/V07/822/59/PDF/V0782259.pdf?OpenElement
(UNCITRAL Future Work).
Smith, Brian W. and Kiefer, Kimberly B., April 1999, 116 “"Recent Developments in
Electronic
Authentication: the Evolution Role of the Certification Authority�?, Banking Law
Journal 341
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United Nations Convention on the Use of Electronic Communications in International
Contracts,
adopted by the General Assembly on 23 November 2005, available at:
http://www.uncitral.org/uncitral/en/uncitral_texts/electronic_commerce/
2005Convention.htm
l
van Cutsem, Jean-Pierre, “E Commerce in the World- Aspects of Comparative Law�?
Wilson, Stephen, (2005), “Guidelines on how to determine Return on Investment in
PKI�?,
OASIS PKI White Paper, Version 1.4.

General References
Baker & Mckenzie: http://www.bakernet.com/ecommerce/germany-t.htm
For E signature in South Korea:
For E signature legislation in Mexico (in Spanish), see:
For E signature/commerce legislation in Mauritius, see:

http://www.lowtax.net/lowtax/html/jmuecom.html
On list on countries with e signature legislation, see:
http://rechten.uvt.nl/simone/ds-new.htm
www.gov.mu/portal/goc/ncb/file/eta.pdf

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 ANNEX 1

ENABLING ENVIRONMENT BENCHMARKING MATRIX

AUSTRIA

Legal Basis Austrian Federal Electronic Signature Law (2000);

Applicable to “closed systems, insofar as the parties
within the
system have agreed�? and in open transactions with
courts and
other authorities.
Exceptions: legal transactions under family and
inheritance
laws; legal transactions requiring official
certification, judicial or
notarial authentication, land or companies’
registration;
guarantee declarations
Institutional Arrangements The Law includes duties for Certification Service
Providers to
issue certificates; the Law has provisions on the
supervision of
these CSPs by the Telekom Control Kommission (TCK).
Prior
authorization is specifically prohibited. CSPs require
no special
permit to establish their activities but all CSPs must
notify the
TCK which acts as a supervisory and monitoring body,
supervising all CSPs
Security The law provides for “Basic�? and “Secure�? –AES and
which are
based on “Qualified Certiciates�? and created with
security
requirements
Party Autonomy Up to parties to agree
Interoperability The Law has guidelines on the acceptance of foreign
certificates.
(cross border recognition) Certificates from EU countries are tantamount to
Austrian
certificates. Certificates from third party countries,
which can be
validated in Austria, are recognized. Qualified
certificates from
third party countries are recognized if conditions
similar to EU
Directive are fulfilled, and provided their validity
can be
verified.
Interoperability Interoperability promoted through open specifications
and
(cross certification) voluntary standards

E Government E signature legislation (the 2000 Law) is silent. But

e-
transactions in government are governed separately by
the “E
Government Act�?
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BRAZIL

Legal Basis There are no specific laws in Brazil that deal

with electronic
commerce. In the absence of specific laws,
electronic contracts
are governed by the general principles set out
in the 1916
Brazilian Civil Code (CC), the 1850 Brazilian
Commercial Code
and the 1990 Brazilian Consumer Code (Consumer
Code),
among other relevant statutes54.Several
statutes regulate the use
of e signatures; But an E signature Bill is
still pending before
Congress
Institutional Arrangements A Government/Private sector committee
regulates all
Certification Service Providers activities.
But there are other
lower level entities that regulate the
issuance of certificates
Security In some, especially bank operations
Party Autonomy Brazil laws with a bearing on the e signature
provide the
possibilities of the parties to elect whether
to use e signature
Interoperability Efforts are underway to achieve cross border
interoperability;
there is also a committee to promote internal
operability. But
note that Brazilian law does not associate the
legal validity of a
document with the use of a specific
certification or e-signature
system provided that the parties accept an
alternative means of
confirming authenticity and integrity. Thus,
there are no specific
rules in Brazil that regulate the validity of
foreign e-signatures or
certifications.
E Government E signature applications used in Banks
(including Central bank)
and government entities (e.g. tax revenue
authority)

54
Geoges Fischer article, p.166
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CANADA
Legal Basis The Personal Information Protection and Electronic
Documents Act is the Federal law; there are various
provincial
laws on e-signatures, but these statutes do not apply
to elections
legislation, wills and trusts, powers of attorney,
documents
relating to interest in land matters and negotiable
instruments
Institutional Arrangements
Security
Party Autonomy The legislation does not require use without a
person’s consent;
parties can opt out.
Interoperability There seems to be no provision in the federal law
relating to
(cross border recognition) recognition of foreign certificates and electronic
signatures. The
legislation does contain, however, provisions on
place of
sending and receipt of electronic communications
Interoperability
(cross certification)
E Government

GERMANY

Legal Basis Law on Framework Conditions for Electronic Signatures;

unless prescribed by law, e signature use is voluntary
Institutional Arrangements Certification Service Providers could be natural persons
or legal
entities who issue certificates. No need for approval to
operate
certification services but must be accredited by
“Competent
Authority�? under Germany’s Telecommunications law; the
‘Competent Authority’ issues accredited CSPs with
qualified
certificates they need; Competent Authority is
responsible for
supervising the Act and CSPs. Germany utilizes a Bridge
CA.
Security “Basic�? –AES (same requirements as in the Directive)
and
Qualified Signatures (AES based QC and created by an
SSCD)
Party Autonomy Unless prescribed by law, use of e signatures is
voluntary
Interoperability E signatures for which a foreign certificate has been
issued by an
(cross border recognition) EU member country or a signatory to Treaty on European
Economic Area are the equivalent of qualified e
signatures in
Germany if they correspond to EU Directive on e
signatures.
There are additional requirements for e signatures from
third party
countries.
Interoperability Several bodies have been established to promote
interoperability
(cross certification)
E Government Yes
Additional requirements: long term provable signatures
are
mandatory for publics entities for a few public
administration
applications
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MALAYSIA

Legal Basis Digital Signature Act 1997

Institutional Arrangements Minister appoints a Controller Of Certification
Authorities for
the purposes of monitoring and overseeing the
activities of
certification authorities. It is mandatory for
Certification
Authorities to be licensed; Minister has the power to
set
qualification requirements for CA; the Act also
restricts the use
of the term “certification authority�?; contains many
regulations
on revocation/refusal of license
Security The Act has several provisions on security of
signatures, liability
and control of private key; presumptions in favour of
valid
signatures; law is based on public key infrastructure
Party Autonomy Variation by agreement is permissible
Interoperability Controller may recognize, by order published in the
Gazette,
(cross border recognition) certification authorities licensed or otherwise
authorized by
governmental entities outside Malaysia that satisfy
the
prescribed requirements
Interoperability No provisions
(cross certification)
E Government

MAURITIUS

Legal Basis Electronics Transactions Act (2000); applies to

electronic
records and electronic signatures to a transaction but
does not
apply to wills, negotiable instruments, power of
attorney or real
property contracts
Institutional Arrangements The Act establishes the public office of Controller of
Certification Authorities responsible for licensing
and
monitoring Certification Authorities
Security Secure electronic signatures provided for; there is a
presumption
in favour of electronic signatures; trusted CA
Party Autonomy Parties are at liberty to vary provisions of the Act
Interoperability
(cross border recognition)
Interoperability
(cross certification)
E Government The Act provides for the use and recognition of e
signatures and
records in the public sector
MEXICO
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Legal Basis 2003 E signatures Code under the Code of Commerce, a
federal statute, with wide sphere of application. No
specific
exceptions as to what documents may not be subject to
the law
Institutional Arrangements CSP are heavily regulated in Mexico and there are
stringent
requirements to be met to be a CSP. The Secretariat of
Economy
is entrusted with enforcing the Code’s provisions. It
acts as an
Accrediting Authority; CSPs must obtain prior
accreditation
from the Secretariat and must notify it of the
beginning of their
certification services activities within 45 days.
Security The Code provides for ‘reliable’ and ‘advanced’
signatures with
different requirements. Presumption is in favour of
reliable
signatures. Note that unlike other countries or the
Model Law,
the Code establishes requirements that certificates
must meet for
them to be valid.
Party Autonomy Although the Code does not make reference to parties’
rights to
contractually modify or exclude the applicability of
its
provisions, its generally considered that parties can
amend or
derogate from the provisions to the extent not
contrary to order
public
Interoperability Foreign Certificates/signatures recognized on the
principle in
(cross border recognition) recognizing the legal effects of foreign certificates
or e
signatures, only their reliability is relevant. A
foreign certificate
will have same effect as Mexican certificate if it
complies with
the level of reliability of Mexican certificates.
Interoperability
(cross certification)
E Government Public transactions are covered under the law

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SINGAPORE

Legal Basis Electronic Transactions Act (the “Act�?) of Singapore

aims to
eliminate barriers to electronic commerce resulting from
uncertainties over writing and signature requirements
Exceptions: Doesn’t apply to laws requiring writing or
signatures
in wills, negotiable instruments, indentures/power of
attorney,
contract of sale or conveyance of real property
Institutional Arrangements Certification Authority (CA) issues certificates to
prospective
subscribers; it is not mandatory but done on request.
(Seems there
are benefits for licensed CSP); CA prescribes duties of
Subscribers; Minister appoints Controller of CAs for
certifying/monitoring CAs
Security See provisions under Part VI (person relying on e
signature
assumes the risk. The Act provides for different
treatment for
“electronic signatures�? and for “secure electronic
signatures�?
which are more secure and are given additional
presumptions (e.g.
of integrity, of the authority of person who created it
etc).
Party Autonomy Parties are free to vary any provision of the Act
Interoperability Yes: Minister may, by regulations, provide that
Controller of CAs
(cross border recognition) recognize foreign CAs that satisfy the requirements for
e signature
certificates under the Act
Interoperability
(cross certification)
E Government Any ministry or department of Government that accepts
the filing
of documents/issues permits, licenses or approvals or
provides for
method and manner of payment, may do so by electronic
records/form

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SOUTH AFRICA

Legal Basis The Electronic Communications and Transactions Act, 2002

(the “Act�?); If type of signature not specified,
advanced e
signatures recognized; The Act is not mandatory; Applies
to any
data message or electronic transaction except where
legislation
provides otherwise
Institutional Arrangements The Director-General of Department of Communications
acts as
Accreditation Authority; but accreditation is voluntary;
AA plays
supervisory or monitoring role
Security Provides for “advanced�? e signatures unless the parties
require
otherwise
Party Autonomy Provisions of e signatures fall within a part of the Act
which is
mandatory and cannot be varied by agreement.
Interoperability Minister may (by notice in Gazette) recognize
accreditation or
(cross border recognition) authentication products/services from any foreign
jurisdiction

Interoperability
(cross certification)
E Government E Government services are recognized: any public body
that
accepts the filing of documents or requires that
documents be
created or issues any permit/license or approval or
provides for a
manner of payment may do so through data messages or
electronic
means

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SOUTH KOREA

Legal Basis Has two laws: The Basic Law on Electronic Commerce
and
the Electronic Signature Act (1999)
Institutional Arrangements The Act mandates the Government (Ministry of
Information) to
designate an authorized certification authority to
ensure the
security and reliability of electronic commerce and
to promote
sound transactions. The Act designates KISA (Korean
Information Security Agency) as the body responsible
for
supervising e signature certification services.
Security The Act distinguishes between accredited electronic
signatures
(based on an accredited certificate and meeting
specified security
requirements) and other e signatures.
Party Autonomy
Interoperability The Act provides that the Ministry of information
shall promote
(cross border recognition) activities aimed at achieving smooth
interoperability of e
signatures, domestically and internationally.
Interoperability The Act provides that the government may enter into
agreements
(cross certification) with other foreign governments for mutual
recognition of e
signatures. Such agreement shall grant “the same
legal status or
effect�? to a foreign CA or e signatures or
certificate issued by a
foreign CA as the Korean certificate or e signature.
E Government An “E Government Act�? was enacted to promote
efficiency in
public services

THAILAND

Legal Basis Electronic Transactions Act; applies to all civil and

commercial
transactions except those expressly excluded by a Royal
Decree
Institutional Arrangements There is an Electronic Transactions Commission
(consisting of
Minister and others appointed by Cabinet) with authority
to “issue
rules or notifications relating to e signature�? in
compliance with
the Act; ETC has duty to monitor and supervise e
transactions
business;
To maintain “financial and commercial stability “ and
“strengthening the credibility�? of e transactions,
Royal Decree
may require prior notification/registration of CSPs
Security Ordinary e signatures provided for;
Party Autonomy The requirements in the Act on e signatures “does not
limit that
there is no other way to prove the reliability of an e
signature�?
Interoperability An e signature created/used in a foreign country shall
have same
(cross border recognition) legal effect as those created in Thailand if the level
of reliability
used in creating or using such e signature is not lower
than as
prescribed in the Act

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Interoperability Promoted: Certificate of e signature is effective
regardless of
(cross certification) geographic location of where certificate is issued
or the e signature
is created or used; and regardless of geographic
location of place
of business of issuer of certificate or signatory.
E Government The Act applies to transactions (applications,
payments,
permissions, registrations etc) of the affairs of
the State or State
agency;
Additional Requirement: Royal Decree may require
the CSP to the
public to notify or apply for registration or prior
to commencement
of business with public sector
UNITED KINGDOM

Legal Basis Electronic Communications Act 2000 ; The

Electronic
Signatures Regulations 2002; and also the
Electronic
Commerce (EC Directive) Regulations 2002; the e
signature
regulations are not limited in their scope of
application

Institutional Arrangements Secretary of State oversees/ reviews the carrying

on of activities
of certification-service-providers who are
established in the
United Kingdom and who issue qualified
certificates to the
public
Prior authorization of CSPs is not prohibited. but
there is no
notification for CSPs; CSPs subject to
supervision; CSPs on
tScheme are monitored for adherence to Code of
Conduct. the
law does not mention voluntary accreditation, but
there’s an
industry voluntary self regulated scheme (tScheme)
Security Provides for two types of signatures: “Basic�? and
AES similar to
the EU Directive; also note: Certificate and
Qualified Certificate
are provide for with different requirements
Party Autonomy English law places great deal of emphasis on
freedom to
contract. Thus parties may agree to contract out
of any of the
provisions
Interoperability None specific provision55. But note that the
definition of
(cross border recognition) “Qualified Certificate�? under the Regulations
does not make
reference to the jurisdiction of the certificates
incorporation thus
there is nothing to limit the scope of the
legislation to
“domestic�? e signatures only56
Interoperability Equal treatment of signature technologies is
recognized
(cross certification)
E Government Available; there are specific requirements for the
use of e
signatures in the public sector. A government
‘gateway’ has
been established to provide a centralized
registration for e
government services
55
EU report p. 216
56
Campbell, E Commerce and E signatures, p. 663
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 ANNEX 2

Brazil Examples of Digital Certificates

 Sistema de Pagamentos Brasileiro http://www.bacen.gov.br/?SPB

o Central Bank

 e-CPF and e-CNPJ / Certificados Digitais

http://www.receita.fazenda.gov.br
o Secretaria da Receita Federal ( all federal tax and some social
contributions )

 Nota Fiscal Eletrônica http://www.nfe.fazenda.gov.br/portal

o Ministério da Fazenda ( ICMS, it is a VAT like tax divided among
Federal
Governrnent and States )

 Bank Services
o Bradesco http://www.bradesco.com.br/br/pessoa-fisica/prods
o Bradesco http://www.bradesco.com.br/pj/conteudo/pergunt
o Unibanco http://www.unibanco.com.br/epd/sgr/cer/index/.asp

 Labor Courts e- DOC http://www.trt4.gov.br/edoc/certificados/htm

 Federal Courts http://www.justicafederal.gov.br/portal/publicacao/

 Superior Education / Ministério da Educação

o http://emec.mec.gov.br
o http://prouni-inscricao.mec.gov.br/prouni/digital/asp
o http://prouni-inscricao.mec.gov.br/prouni/passo2.asp

 Caixa Economica Federal ( social programs )

o http://icp.caixa.gov.br

 Insurance Brokers / Insurance Services

o http://www.acfenacor.com.br/conhecer.htm
o http://www.corretoresdeseguros.com.br/new/tecnologia/certificacao-
digital.php

 Notarial Services
o http://www.notariado.org.br/soft.asp
o http://www.anoregpr.org.br/certificacaodigital.htm

 Agrobusiness
o http://www.agrolivre.gov.br/modules/tinycontent/index.php?id=3

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 ANNEX 3

Examples of Costs Structures

A. United States

Note: The full table is available online at: http://aces.orc.com/pricing.html

Commercial
Government

Clin
Description Clin # Price
Price

#
Individual and Business Representative Certificates (Level 3)1
Per Certificate
Digital Signature Certificates 0051a
0002

Under 500 $80.00

$76.00

500 to 1,000 $75.00

$72.00

1,001 to 10,000 $65.00

$63.00

10,001 to 25,000 $45.00

$44.00

over 25,000 $35.00

$34.00

Encryption Certificates (no escrow) 0051b

Under 500 $80.00

$76.00

500 to 1,000 $75.00

$72.00

1,001 to 10,000 $65.00

$63.00

10,001 to 25,000 $45.00

$44.00

over 25,000 $35.00

$34.00

Digital Signature Certificates, ID Proofing by Government 0051c

Under 500 $50.00

$49.00

500 to 1,000 $45.00

$44.00

1,001 to 10,000 $40.00

$39.00

10,001 to 25,000 $35.00

$35.00

over 25,000 $30.00

$29.00

Encryption Signature Certificates, ID Proofing by 0051d

Government (no escrow)
Under 500 $50.00
$49.00

500 to 1,000 $45.00

$44.00

1,001 to 10,000 $40.00

$39.00

10,001 to 25,000 $35.00

$35.00

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 over 25,000
$30.00 $29.00

Certificates, Enterprise Service Level Agreement2, (no 0051e

escrow)
First 100 Users
$150.00 $145.00

User 101 to 500

$110.00 $105.00

User 501 to 1,000

$80.00 $77.00

User 1,001 to 5,000

$60.00 $58.00

User 5,001 to 10,000

$45.00 $44.00

User 10,001 to 25,000

$35.00 $34.00

over 25,000
$25.00 $24.00

Agency Application Certificate

N/A 0003 $150.00

Supplemental PKI Services

N/A 0004 refer to GS-

35F-164J
Technology Updates
N/A 0005 refer to GS-

35F-164J
Ad Hoc Data Collection, Analysis, and Dissemination
N/A 0006 refer to GS-

35F-164J
Component and Code Signing certificates (Level 3)1
Per Certificate
Application Digital Signature Certificates 0052a
$500.00 0008a $490.00

Application Encryption Certificates 0052b

$500.00 0008a $490.00

Domain Controller Certificates 0052c

$500.00 0008a $490.00

Code Signing Certificates (includes FIPS 140 - 1/2 Level 2 0052d

$500.00 0008a $490.00
Hardware Token)

Hosted Certificate Validation Services

Monthly
 Certificates OCSP Validation Responder Service (Monthly) 0053a
0009a

Under 1,000 users

$6,600.00 $6,600.00

1,001 to 10,000
$13,200.00 $12,000.00

10,001 to 25,000
$26,400.00 $24,000.00

25,001 to 50,000
$52,800.00 $48,000.00

over 50,000
$105,600.00 $96,000.00

Certificate Validation Transaction Based3 0053b

0001

Per Transaction

Validation Volume under 100,000

$1.35 $1.261212

Validation Volume 100,000 to 250,000

$1.15 $1.051010

Validation Volume 251,000 to 500,000

$1.00 $0.892984

Validation Volume 501,000 to 1,000,000

$0.85 $0.758719

Validation Volume 1,000,000 to 5,000,000

$0.75 $0.657019

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 Validation Volume 5,000,000 to 10,000,000
$0.65 $0.579669

Validation Volume 10,000,000 to 25,000,000

$0.60 $0.520882

Validation Volume 25,000,000 to 50,000,000

$0.55 $0.4765550

Validation Volume over 50,000,000

$0.50 $0.443775

Validation Volume over 100,000,000

$0.420489

Relying Party Certificate Validation Enabling Kits4

Per Kit

Server Kit (for Web Servers, Mail Servers, etc) 0054a

$5,280.00 0010a $4,800.00

Enterprise Windows Domain Controller Kit 0054b

$2,640.00 0010b $2,400.00

Client Kit (IE, Outlook, Outlook Express)

Per Kit

10 User Kit 0054c

$550.00 0010c $500.00

50 User Kit 0054d

$2,090.00 0010d $1,900.00

250 User Kit 0054e

$8,140.00 0010e $7,400.00

1000 User Kit 0054f

$20,900.00 0010f $19,000.00

Certificate Registration Kit for User Database 0054g

$16,500.00 0010g $15,000.00

Training/Registration Services one (1) day training (Maximum

Per Day
class size of 10)
LRA Training and Certification of trusted individuals in your 0055a
$2,500.00 0011a $2,300.00
organization to streamline registration process
Recovery Process associated with an (optional) tailored 0055b
$2,500.00 0011b $2,300.00
organizational private key archival and recovery system for
encryption private keys
PKI Sponsor training and certification of trusted individuals 0055c
$2,500.00 0011c $2,300.00
in an organization to request, renew and use component
certificates
Code Signing Attribute Authority (CSAA) training and 0055d
$2,500.00 0011d $2,300.00
 certification of trusted individuals granted signature
authority for an organization to authorize applications or
individuals for a code-signing certificate
Key Recovery Official Training and certification of trusted 0055e
$2,500.00 0011e $2,300.00
individuals in accordance with the requirements of the U.S.
Government Key Recovery Policy (KRP)
On-site Registration Authority Daily Rate, per day 0055f
$2,500.00 0011f $2,300.00

Technology Support
Per Hour

Expert Level Hourly Labor Rate 0056a

$305.00 refer to GSA

Schedule
Senior Level Hourly Labor Rate 0056b
$205.00 refer to GSA

Schedule

Per Year

Gold Technical Support for all supplies and services5 0056c 20% of
total 0012a 20% of total

cost cost
Platinum Technical Support for all supplies and services6 0056d 30% of
total 0012b 30% of total

cost cost

User Hardware Tokens (FIPS 140-1/2 Level 2)7

Per User

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 Smartcard (Token, USB Reader, and Software) 0057a $102.50 0013a
$100.50

USB Token (Token, Reader, and Software) 0057b $80.50 0013b

$78.50

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 B. State of Washington Pricing (2003)

Source: State of Washington, Master Contract T00-Mst-001 For Certification

Authority And
Public Key Infrastructure Services, Schedule A – Authorized Product And Price List,
July 2003

Initial Certificate Pricing For High and Intermediate Assurance Level Certificates,
prices below
include the cost of hardware and software cryptographic modules as required by the
Washington State
Certificate Policy. Standard Assurance Level Certificates use an Internet Browser
or Roaming software
client to manage and protect Private Keys and Certificates and therefore do not
require the purchase of
special hardware or software for Private Key protection.

High and Intermediate Assurance Level Certificates

Prices below include the Annual Subscription Service Fee*, two Certificates (one
for signing and one for
encryption), plus one of the following hardware or software cryptographic (key
protection) module
combinations. Costs for encryption key recovery services vary, and are listed in
“Other Services�? below:
High Intermediate
Standard

Hardware-Based Key Protection Solutions

Datakey Model 330 Smartcard, Smartcard Reader and
$131.00
$121.00 N/A
Software
Rainbow Technologies iKey2032 USB Key Fob, Software $85.00
$75.00 N/A
Rainbow Technologies iKey2032 USB Key Fob, Software
and USB Extension Cable $90.00
$80.00 N/A

$10.00
Standard Assurance Level Certificates

Browser-Based Certificates
Price includes the Annual Subscription Fee*, and issuance of a single signing
Certificate (which
may also be used for authentication and access control). Browser-based Standard
Assurance
Level Certificates are stored in a workstation’s browser and requires the use of
Microsoft
Internet Explorer (IE) Version 5.xx or higher or Netscape Version 4.7 or higher
browser that
support 128-bit encryption (browser is not included in the price). Key recovery
services are not
offered for browser-based Standard Assurance Level Certificates.
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Roaming Certificates
Price includes the Annual Subscription Fee*, and issuance of a single signing
Certificate (which may also
be used for authentication and access control). Uses an unlimited-use downloadable
“roaming�? client to
allow an individual to access their Private Key and digital Certificate from any
compatible workstation
connected to the Internet. Uses a familiar user name and password interface and
provides the user the
ability to reset their password up to five times per year. Requires Windows 98 or
higher and Internet
Explorer 5.xx and higher or Netscape 4.7. Key recovery services are not offered for
Standard Assurance
Level Roaming Certificates.

Certificate Renewal Pricing

Prices below assume that, in the case of High and Intermediate Assurance Level
Certificates, the
hardware or software cryptomodule, as required by Washington State Certificate
Policy, has already been
obtained. Prices below pertain to policy-compliant Subscribers who are renewing
their Certificates for
another year, or who need to replace a previously-issued Certificate.

High and Intermediate Assurance Level Certificates

Prices below include the Annual Subscription Fee* and two Certificates (one for
signing and one for
encryption). Costs for encryption key recovery services vary, and are listed in
“Other Services�? below:
High Intermediate
Standard

Hardware-Based Key Protection Solutions

Datakey Model 330 Smartcard. Smartcard Reader and
Software $35.00 $25.00
N/A
Rainbow Technologies iKey2000 USB Key Fob, Software
$35.00 $25.00
N/A

$10.00
Standard Assurance Level Certificates

Browser-Based Certificates
Price includes the Annual Subscription Fee*, and issuance of a single signing
Certificate (which
may also be used for authentication and access control). Browser-based Standard
Assurance
Level Certificates are stored in a workstation’s browser and requires the use of
Microsoft
Internet Explorer (IE) Version 5.xx or higher or Netscape Version 4.7 or higher
browser that
support 128-bit encryption (browser is not included in the price). Key recovery
services are not
offered for browser-based Standard Assurance Level Certificates.
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$10.00
Roaming Certificates
Price includes the Annual Subscription Fee*, and issuance of a single signing
Certificate (which
may also be used for authentication and access control). Uses an unlimited-use
downloadable
“roaming�? client to allow an individual to access their Private Key and digital
Certificate from
any compatible workstation connected to the Internet. Uses a familiar user name and
password
interface and provides the user to reset their password up to five times per year.
Requires
Windows 98 or higher and Internet Explorer 5.xx and higher or Netscape 4.7. Key
recovery
services are not offered for Standard Assurance Level Roaming Certificates.

*Annual Subscription Service Fee Includes: Customer Service Support, Directory

Services, Maintenance Fees for All
Components, Online Registration, Subscriber Agreement, Unlimited Repository Access
24x7 for CRL checking, Revocation
Services, Certificate Validity Period of One Year.
Encryption Key Recovery Services for High and Intermediate Assurance Level
Certificates are available as provided in
“Other Services�?

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