NS-009: Permit Log Storage Systems to be operated in Third Party-Controlled Environments - #59
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CBonnell wants to merge 16 commits into
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NS-009: Permit Log Storage Systems to be operated in Third Party-Controlled Environments#59CBonnell wants to merge 16 commits into
CBonnell wants to merge 16 commits into
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Co-authored-by: Corey Bonnell <dev@cbonnell.com>
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qaalhajri
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May 26, 2026
| * Security Support System. | ||
| * Root CA System (Air-Gapped and otherwise); | ||
| * Security Support System; or | ||
| * Logging System. |
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I'm concerned that some interpretation may take the Logging System that is in a Third-Party Environment as a system in scope that needs to meet all the NSR requirements 1-4. This would be difficult as you'll need to validate/audit the Third Party Controlled Environment itself.
Some alternative options:
- Could we break out the logging system from CA Infrastructure and define the requirements for logging system comprehensively separately in section 5/section 6 respectively?
- Update each requirement section where "CA Infrastructure" is referenced to "CA Infrastructure in a CA Controlled Environment"
qaalhajri
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May 26, 2026
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| Logging Systems MUST be in: | ||
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| 1. a CA-Controlled Environment; |
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If it is in a CA-controlled environment, what requirements must the logging system follow?
qaalhajri
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May 26, 2026
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| ## 6.1 Risk Assessment | ||
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| The CA MUST perform a risk assessment of the service provider of the Third Party-Controlled Environment. The risk assessment MUST cover topics applicable to the services being used and MUST cover the CA’s considerations and criteria. The CA MUST document the evidence relied upon in performing the risk assessment, which MAY include independently audited or certified reports. The risk assessment SHOULD cover: |
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Are there a common criterion/standard for when a risk is acceptable or not acceptable. If it becomes unacceptable, is there a timeline to remediate?
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