Amazon Trust Services
Certification PracticeStatement
Version 1.0.6

11. INTRODUCTION
1.1 Overview
Amazon Trust Services (“Amazon”) has established the Amazon Public Internet Public Key Infrastructure(“Amazon PKI”). This CPS outlines the principles and practices related to the Amazon PKI certificate issuanceservices and describes the practices used to comply with the Amazon CP and other applicable policies.
This practice statement is designed to be read in conjunction with the Amazon Certificate Policy. All definedterms and acronyms in the CP have the same definitions in this document unless redefined in §1.6 of thisdocument.
The Amazon PKI conforms to the current version of the guidelines adopted by the Certification Authority/
Browser Forum (“CAB Forum”) when issuing publicly trusted certificates, including the Baseline
Requirements for the Issuance and Management of Publicly Trusted Certificates (“Baseline Requirements”),
the Guidelines for Extended Validation Certificates (“EV Guidelines”) and the Guidelines for Extended
Validation Code Signing (“EV Code Signing Guidelines), each of which are published at https://www.cabforum.org. If any inconsistency exists between this CPS and the Baseline Requirements, the EV
Guidelines, or EV Code Signing Guidelines then the associated requirement or guideline document shall takeprecedence.
This CPS is only one of several documents that control Amazon PKI certification services. Other important
documents include both private and public documents, such as the CP, Amazon’s agreements with its
customers, and Amazon’s privacy policy. Amazon may provide additional certificate policies or certification
practice statements. These supplemental policies and statements are available to applicable users or relying
parties. The document name, location of, and status, whether public or confidential, are detailed below. This
is not an exhaustive list.
Document

StatusLocation

Amazon Certificate Policy

PublicAmazon Repository

Amazon Certification PracticeStatement

PublicAmazon Repository

Subscriber Agreement

PublicAmazon Repository

Terms of Use

PublicAmazon Repository

Amazon Privacy Policy

Publichttps://www.amazon.com/gp/help/customer/
display.html?nodeId=468496

CA Procedure Documents

Confidential Presented to auditors accordinglyThis CPS, related agreements, and Certificate policies referenced within this document are available online athttps://www.amazontrust.com/repository.
This work is licensed under the Creative Commons Attribution-NoDerivatives 4.0 International License. Toview a copy of this license, visit http://creativecommons.org/licenses/by-nd/4.0/ or send a letter to Creative
Commons, PO Box 1866, Mountain View, CA 94042, USA.

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Pursuant to the IETF PKIX RFC 3647 CP/CPS framework, this CPS is divided into nine primary
components that cover the security controls and practices and procedures for certificate issuance services
within the Amazon PKI. To preserve the outline specified by RFC 3647, section headings that do not apply
have the statement “Not applicable” or “No stipulation.”
This document is the CPS for the following Certification Authorities:
CA Type CA Distinguished Name

Key pair type
SHA-256 Key
and parameters Fingerprint

Validity Period

C=US
Root CA O=Amazon
CN=Amazon Root CA 1

fbe3018031f9586b
RSA, n has 2048- cbf41727e417b7d1
bits e=65537
c45c2f47f93be372
a17b96b50757d5a2

2015-05-26 00:00:00
GMT to 2038-01-17
00:00:00 GMT

C=USRoot CA O=Amazon
CN=Amazon Root CA 2

7f4296fc5b6a4e3b
RSA, n has 4096- 35d3c369623e364ab1af381d8fa71215
bits e=65537
33c9d6c633ea2461

2015-05-26 00:00:00
GMT to 2040-05-26
00:00:00 GMT

C=USRoot CA O=Amazon
CN=Amazon Root CA 3

36abc32656acfc64
EC, NIST P-256 5c61b71613c4bf21
c787f5cabbee4834
curve
8d58597803d7abc9

2015-05-26 00:00:00
GMT to 2040-05-26
00:00:00 GMT

C=USRoot CA O=Amazon
CN=Amazon Root CA 4

f7ecded5c66047d2
EC, NIST P-384 8ed6466b543c40e0
curve
743abe81d109254d
cf845d4c2c7853c5

2015-05-26 00:00:00
GMT to 2040-05-26
00:00:00 GMT

C=US
ST=Arizona
28689b30e4c306aa
L=Scottsdale
O=Starfield Technologies, RSA, n has 2048- b53b027b29e36ad6
Root CA
dd1dcf4b95399448
bits e=65537
Inc.
2ca84bdc1ecac996
CN=Starfield Services
Root Certificate Authority- G2

2009-09-01 00:00:00
GMT to 2037-12-31
23:59:59 GMT

Effective June 10, 2015, the Starfield Services Root Certificate Authority - G2 certification authority operates
under this CPS. Prior to such date, the Starfield Services Root Certificate Authority - G2 certification authority
was operated under the Starfield Technologies, LLC Certificate Policy and Certification Practice Statement.

1.2 Document name and identification
This document is the Amazon Certification Practices Statement and was approved for publication by the
APPMA. The following revisions were made to the original document:
Date

Changes

2015-05-26 Initial release.

Version
1.0.1

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2015-06-10 Added new root.

1.0.2

2015-10-21 Updated to Amazon Trust Services and to use standard policy identifiers.

1.0.3

2015-12-08

Updated validation processes for wildcard DNs, email addresses, and Subordinate
CAs.

1.0.4

2017-01-12 Yearly update

1.0.5

2018-01-15 Yearly update, including CAA information

1.0.6

The OID for this CPS is 1.3.187.129.2 {iso(1) identified-organization(3) amazon(187) documents(129) cps(2)}Subsequent revisions to this CPS may have new OID assignments.

1.3 PKI participants
1.3.1 Certification authorities
Amazon is a CA that issues digital certificates. As a CA, Amazon performs functions associated with Public
Key operations, including receiving certificate requests, issuing, revoking and renewing a digital certificate,and maintaining, issuing, and publishing CRLs and OCSP responses. General information about Amazon
products and services is available at www.amazon.com.
CAs issue certificates in accordance with the Amazon CP. Subscriber certificates are only issued from Root
CAs as necessary to meet the User Agent Verification Requirements of Appendix C of the Baseline
Requirements and may only be issued to Amazon Trust Services or an affiliated company. Amazon Trust
Services or an affiliated company must have the right to use or legitimate control of all domain names and IP
addresses in such subscriber certificates.

1.3.2 Registration authorities
Amazon may delegate the performance of certain functions to an RA and/or other third parties (each a“Delegated Third Party”) to request certificates and/or perform identification and authentication for end user
certificates. The specific role of an RA or Delegated Third Party varies greatly between entities, ranging from
simple translation services to actual assistance in gathering and verifying Applicant information. Some RAs
operate identity management systems and may manage the certificate lifecycle for end users. Amazon
contractually obligates each Delegated Third Party to abide by the policies and industry standards that are
applicable to that Delegated Third Party’s role in certificate issuance, management, revocation or otherrelated task that the Delegated Third Party performs.
RA personnel involved in the issuance of publicly trusted SSL Certificates must undergo training as specified
in 5.3.3 Training Requirements set forth in Section 5.3.3 hereof. An RA or identity management system
supporting a particular community of interest with custom identity vetting practices that differ from thosefound herein may submit documentation to the APPMA for review and approval. The documentation must
contain sufficient detail to ensure that all tasks required by the CP will be performed.

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1.3.3 Subscribers
Subscribers use the Amazon PKI to support transactions and communications. Subscribers are not always theparty identified in a certificate, such as when certificates are issued to an organization’s employees or when
the subject owner has granted control of the subject to the subscriber. Prior to verification of identity andissuance of a certificate, a Subscriber is an Applicant.

1.3.4 Relying parties
Relying Parties must check the appropriate CRL or OCSP response prior to relying on information featured
in a certificate. The location of the CRL distribution point and OCSP responder is detailed within thecertificate.

1.3.5 Other participants
Other participants include Accreditation Authorities (such as Policy Management Authorities, Federation
Operators, Application Software Vendors, and applicable Community of Interest sponsors); Bridge CAs andCAs that cross certify Amazon CAs as trust anchors in other PKI communities, CMAs, RSPs, CSAs and TSAs.
If the CA subcontracts CMA, RSP, CSA, TSA, or other functions, the CA ensures that compliance with the CP
is required in the agreement with the subcontractor. The CA may use a practices statement of thesubcontractor as evidence of compliance if, and only if, the subcontractor’s practices are audited by anindependent external auditor on at least an annual basis and the subcontractor submits the results of each
audit to the CA.

1.4 Certificate usage
A digital certificate (or certificate) is formatted data that cryptographically binds an identified Subscriber witha Public Key. A digital certificate allows an entity taking part in an electronic transaction to prove its identity
to other participants in such transaction. Digital certificates are used in commercial environments as a digital
equivalent of an identification card.

1.4.1 Appropriate certificate uses
Certificates issued pursuant to this CPS may be used for all legal authentication, encryption, access control,and digital signature purposes, as designated by the key usage and extended key usage fields found within thecertificate. However, the sensitivity of the information processed or protected by a certificate varies greatly,and each Relying Party must evaluate the application environment and associated risks before deciding onwhether to use a certificate issued under this CPS.

1.4.2 Prohibited certificate uses
Certificates do not guarantee that the Subject is trustworthy, honest, reputable in its business dealings,
compliant with any laws, or safe to do business with. A certificate only establishes that the information in thecertificate was verified as reasonably correct when the certificate issued.

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Certificates issued under this CPS may not be used (i) for any application requiring fail safe performance suchas (a) the operation of nuclear power facilities, (b) air traffic control systems, (c) aircraft navigation systems, (d)weapons control systems, or (e) any other system whose failure could lead to injury, death or environmental
damage; or (ii) where prohibited by law.
Additionally, Certificates issued under this CPS may not be used for “traffic management” or man-in-themiddle purposes.

1.5 Policy administration
1.5.1 Organization administering the document
This CPS and the documents referenced herein are maintained by the APPMA, which can be contacted at:
Amazon PKI Policy Management Authority
410 Terry Ave. North
Seattle, WA, 98109-5210+1 206 266 1000
Web: www.amazon.com
Email: appma@amazon.com

1.5.2 Contact person
Attn: Amazon Trust Services Legal Department
Amazon PKI Policy Management Authority
410 Terry Ave. North Seattle, WA, 98109-5210+1 206 266 1000
Web: www.amazon.com
Email: appma@amazon.com

1.5.3 Person determining CPS suitability for the policy
The APPMA determines the suitability and applicability of this CPS based on the results andrecommendations received from an independent auditor. The APPMA is also responsible for evaluating andacting upon the results of compliance audits.

1.5.4 CPS approval procedures
The APPMA approves the CPS and any amendments. Amendments are made after the APPMA has reviewed
the amendments’ consistency with the CP, by either updating the entire CPS or by publishing an addendum.
The APPMA determines whether an amendment to this CPS is consistent with the CP, requires notice, or an
OID change.

1.6 Definitions and acronyms
1.6.1 Definitions
Affiliated Organization
An organization that has an organizational affiliation with a Subscriber and that approves orotherwise allows such affiliation to be represented in a certificate.

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Applicant
An entity applying for a certificate.
Application Software Vendor
A software developer whose software displays or uses Amazon certificates and distributes Amazon
root certificates.
Base Domain
A Domain Name which is formed by pruning one or more labels from the left side of a FQDN. Base
Domains do not include public suffixes or any Domain Name which is created by removing one ormore labels from the left side of a public suffix.
CA/Browser Forum
A group made up of Certificate Authorities and Browsers that establish and manage the requirements
all public Certificate Authorities must meet.
Certificate Transparency
An open framework for monitoring and auditing digital certificates.
Crypto-module
A hardware device such as a smartcard, token or hardware security module that generates andmanages cryptographic keys securely.
Entropy
The randomness collected by a system for use in cryptography or other uses that require random data.
Key Pair
A Private Key and associated Public Key.
OCSP Responder
An online software application operated under the authority of Amazon and connected to its
repository for processing certificate status requests.
Private Key
The key of a key pair that is kept secret by the holder of the key pair, and that is used to create digital
signatures and/or to decrypt electronic records or files that were encrypted with the corresponding
Public Key.
Public Key
The key of a key pair that may be publicly disclosed by the holder of the corresponding Private Key
and that is used by a Relying Party to verify digital signatures created with the holder corresponding
Private Key and/or to encrypt messages so that they can be decrypted only with the holder’scorresponding Private Key.
Punycode
Punycode is a way to represent Unicode with the limited character subset of ASCII supported by theDomain Name System.
RA Practices Statement
A statement of the practices, which an RA follows.
Relying Party
An entity that relies upon either the information contained within a certificate or a time stamp token.
Subject
The entity named in the certificate.
Subscriber
As applicable, the entity identified as the Subject in the certificate and/or the entity that contractedwith Amazon for the certificate’s issuance.
Subscriber Agreement

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An agreement that governs the issuance and use of a certificate that the Applicant must read andaccept before receiving a certificate.
Trusted Agent
An accountant, lawyer, notary, postal carrier or any entity certified by a State or National Government
as authorized to confirm identities or other reliable third party.
WebTrust
The current version of the AICPA/CICA WebTrust Program for Certification Authorities.
X.509
The ITU-T standard for Certificates and their corresponding authentication framework

1.6.2 Acronyms
APPMA
Amazon PKI Policy Management Authority
CA
Certificate Authority or Certification Authority
CAB“CA/Browser” as in “CAB Forum”
CMA
Certificate Manufacturing Authority
CP
Certificate Policy
CPS
Certification Practice Statement
CRL
Certificate Revocation List
CSA
Certificate Status Authority
CSR
Certificate Signing Request
ETSI
European Telecommunications Standards Institute.
EV
Extended Validation
FIPS(US Government) Federal Information Processing Standard
FQDN
Fully Qualified Domain Name
FTP
File Transfer Protocol
HSM
Hardware Security Module
HTTP
Hypertext Transfer Protocol
IANA
Internet Assigned Numbers Authority
ICANN

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Internet Corporation for Assigned Names and Numbers
IdM
Identity Management System
IDN
Internationalized Domain Name
IETFInternet Engineering Task Force
ITU
International Telecommunication Union
ITU-T
ITU Telecommunication Standardization Sector
NIST
National Institute of Standards
OCSP
Online Certificate Status Protocol
OID
Object Identifier
PKCS
Public Key Cryptography Standard
PKI
Public Key Infrastructure
PKIX
IETF Working Group on Public Key Infrastructure
RA
Registration Authority
RFC
Request for Comments (at IETF.org)
RSP
Repository Service Provider
SHA
Secure Hashing Algorithm
SSL
Secure Sockets Layer
TLD
Top Level Domain
TLS
Transport Layer Security
TSA
Time-stamp authority
TSP
Time-stamp policy
TSTTime-stamp token
URL
Uniform Resource Locator
UTC
Coordinated Universal Time9

2. PUBLICATION AND REPOSITORY RESPONSIBILITIES
2.1 Repositories
Amazon makes its root certificates, revocation data for issued digital certificates, CPs, CPSs, and standard
Subscriber Agreements available in public repositories. All updates, amendments and legal promotions arelogged in accordance with the logging procedures referenced in section 5.4 of this CPS. Amazon’s legal
repository is located at https://www.amazontrust.com/repository. Amazon publicly trusted root certificatesand its CRLs and OCSP responses are available through online resources 24 hours a day, 7 days a week withsystems that are designed to minimize downtime.
Amazon publishes all Subordinate CA Certificates which are not Technically Constrained Subordinate CA
Certificate and all Cross Certificates it issues. For each such certificate, Amazon includes the certificate, a linkto CPS for the subject of the certificate, and a link to the public attestation of operations of the CA in the
Amazon repository located at https://www.amazontrust.com/repository.

2.2 Publication of certification information
The Amazon certificate services and the repository are on the web at https://www.amazontrust.com/
repository (and via URIs included in the certificates themselves).
Links to test Web Pages demonstrating valid, revoked, and expired certificates are included in the repository.

2.3 Time or frequency of publication
CA certificates are published in a repository as soon as possible after issuance. CRLs are published inaccordance with §4.9.7
Amazon may publish new CRLs prior to the scheduled issuance of the next CRL. New or modified versionsof the CP, this CPS, Subscriber Agreements, or Relying Party representations and warranties (as described in§9.6.4) are typically published within seven days after their approval.

2.4 Access controls on repositories
Read only access to the repository is unrestricted. Logical and physical controls prevent unauthorized write
access to repositories.

3. IDENTIFICATION AND AUTHENTICATION
3.1 Naming
3.1.1 Types of names
Certificates are issued with distinguished names and subject alternative names that comply with the CP.

3.1.2 Need for names to be meaningful
Amazon uses distinguished names that identify both the entity (i.e. person, organization, device, or object)that is the subject of the certificate and the entity that is the issuer of the certificate.

103.1.3 Anonymity or pseudonymity of subscribers
The subscriber is not identified in certificates that do not contain organizationName, surname, or
givenName. Relying parties should treat the subscriber as anonymous.

3.1.4 Rules for interpreting various name forms
Distinguished Names in certificates are interpreted using X.500 standards and ASN.1 syntax. See RFC 2253
and RFC 2616 for further information on how X.500 distinguished names in certificates are interpreted as
Uniform Resource Identifiers and HTTP references.
Certificates do not assert any specific relationship between the subscriber and registrant(s) of DNS name(s)contained in certificates.

3.1.5 Uniqueness of names
No stipulation.

3.1.6 Recognition, authentication, and role of trademarks
Subscribers may not request certificates with content that infringes on the intellectual property rights ofanother entity. Unless otherwise specifically stated in this CPS, Amazon does not verify an Applicant’s rightto use a trademark and does not resolve trademark disputes. Amazon may reject any application or requirerevocation of any certificate that is part of a trademark dispute.

3.2 Initial identity validation
Amazon may use any legal means of communication or investigation to ascertain the identity of anorganizational or individual Applicant. Amazon may refuse to issue a Certificate at its sole discretion.

3.2.1 Method to prove possession of private key
Amazon verifies a digital signature on a signed object containing the matching public key to confirm
possession of the private key. The signed object is normally a PKCS#10 certification request, but may be inother formats.

3.2.2 Authentication of organization identity
Amazon follows the Amazon CP for authentication of organization identification.
Amazon uses the following methods to confirm that the Applicant has control of or right to use Domain
Names:
1. Confirming the Applicant as the Domain Name Registrant directly with the Domain Name Registrar;or
2. Confirming authorization of the Certificate’s issuance directly with the Domain Name Registrant
using a Reliable Method of Communication verified by either (i) communication with the Domain
Name Registrar or (ii) being listed as the contact information for “registrant”, “technical”, or“administrative” contacts listed in the WHOIS record for the Base Domain; or11

3. Confirming authorization for the Certificate’s issuance through an email address created by prepending ‘admin’, ‘administrator’, ‘webmaster’, ‘hostmaster’, or ‘postmaster’ in the local part, followed by
the at-sign (“@”), followed by the Domain Name, which may be formed by pruning zero or morecomponents from the requested FQDN; or
4. Relying upon a Domain Authorization Document that meets the requirements listed below; or
5. Having the Applicant demonstrate control over the FQDN or Base Domain by making an agreed-uponchange to information found to a file hosted in the “/.well-known/cabforum” directory at either the
FQDN or the Base Domain in accordance with RFC 5785; or
6. Having the Applicant demonstrate control over the FQDN or Base Domain by the Applicant making achange to information in a DNS TXT record for the FQDN or Base Domain where the change is arandom number with at least 128 bits of entropy provided to the Applicant by the CA; or
7. Having the Applicant demonstrate control over a FQDN by making an agreed upon change to DNS
records for a Domain Name which is formed by pruning zero or more labels from the left side of therequested FQDN or formed by prepending a label to the left side of the requested FQDN where an
appended label exhibits at least 128 bits of entropy and is provided to the Applicant by the CA; or
8. Having the Applicant demonstrate control over the requested FQDN by the CA confirming, in
accordance with section 11.1.1, the Applicant’s controls the FQDN (or Base Domain of the FQDN)
returned from a DNS lookup for CNAME records for the requested FQDN; or
9. Having the Applicant demonstrate control over the requested FQDN by the CA confirming, in
accordance with section 11.1.2, that the Applicant controls an IP address returned from a DNS lookup
for A or AAAA records for the requested FQDN; or
10. Having the Applicant demonstrate practical control over the FQDN by providing a TLS service on ahost found in DNS for the FQDN and having the CA (i) initiate a TLS connection with the host and (ii)verify a response specified by the CA that exhibits 128 bits of entropy and is a in a format recognized
as a valid TLS response.
Amazon does not use methods 9, 10, or 11 for validating wildcard names.
Amazon uses the following methods to confirm the Applicant has control of or right to use Email Addresses:
1. Confirming authorization of the Certificate’s issuance by contacting the requested email address, or
2. Confirming control of the FQDN in the Domain portion of the Email address using methods 1, 2, 5, 7,
or 8 above.

3.2.3 Authentication of individual identity
Amazon follows the Amazon CP for authentication of individual identification.

3.2.4 Non-verified subscriber information
No stipulation.

3.2.5 Validation of authority
Amazon follows the Amazon CP for validation of authority.

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Amazon allows an Applicant to specify the individuals who may request Certificates. If an Applicant specifies,in writing, the individuals who may request a Certificate, then Amazon will not accept any certificate requests
that are outside this specification. A request to limit authorized individuals is not effective until approved by
Amazon. Amazon will provide an Applicant with a list of its authorized certificate requesters upon the
Applicant’s verified written request.

3.2.6 Criteria for interoperation
Amazon discloses cross certificates by placing copies of the cross certificate in the Repository.

3.3 Identification and authentication for re-key requests
Amazon does not rekey certificates without following the same procedures as issuing a new certificate.

3.3.1 Identification and authentication for routine re-key
As per §3.2.

3.3.2 Identification and authentication for re-key after revocation
As per §3.2.

3.4 Identification and authentication for revocation request
Amazon or an RA authenticates all revocation requests that are at the Subscriber’s request. Amazon may
authenticate revocation requests by referencing the Certificate’s Public Key, regardless of whether the
associated Private Key is compromised.
When the revocation is at the CA’s request, such as for cause in accordance with §4.9, identification andauthentication is not required.

4. CERTIFICATE LIFE-CYCLE OPERATIONAL REQUIREMENTS
4.1 Certificate Application
4.1.1 Who can submit a certificate application
The CA follows the Amazon CP to determine who can submit a certificate application.

4.1.2 Enrollment process and responsibilities
In no particular order, the enrollment process includes:• Submitting a certificate application,• Generating a key pair,• Delivering the public key of the key pair to Amazon,• Agreeing to the applicable Subscriber Agreement, and,13

• Paying any applicable fees.

4.2 Certificate application processing
4.2.1 Performing identification and authentication functions
Amazon or an RA (as described in §1.3.2) verifies the application information and other information specified
in the Amazon CP. As part of this verification, Amazon checks the certificate against an internal database ofpreviously revoked certificates and rejected certificate requests to identify suspicious certificate requests. If
some or all of the documentation used to support an application is in a language other than English, an
Amazon employee, RA, or agent skilled in the language assists in the identification and authentication.
Amazon Root CAs check CAA records prior to issuing certificates unless either (a) the CA or an Affiliate of
the CA is the DNS Operator (as defined in RFC 7719) of the domain’s DNS or (b) a Certificate Transparency
pre‐certificate was created and logged in at least two public logs, and for which CAA was checked.
We look for amazon.com, amazontrust.com, awstrust.com, or amazonaws.com in CAA records. We also may
accept FQDNs which are subordinate to these names (for example aws.amazon.com)

4.2.2 Approval or rejection of certificate applications
Amazon follows the Amazon CP with respect to new gTLDs.
For Applications for a Subordinate CA where the Subordinate CA will not be controlled by Amazon, Amazon
ensures that all the following are true:• The APPMA has approved the Subordinate CA• There is a contract in place requiring the Subordinate CA to comply with CA/Browser Forumguidelines• The CA generated and stores its keys on a HSM that meets the requirements in the CP• The CA had the key generation audited by a qualified auditor. This is not required to be a WebTrust
licensed auditor, but the auditor must meet items 1, 3, 6, and 7 of section 8.2 of the CP.
• If the Subordinate CA certificate is not technically constrained, then the contract requires theSubordinate CA operator to provide evidence of a WebTrust audit with a period ending not more than
one year prior to application or a WebTrust point in time readiness assessment that occurred no morethan one year prior to application. Additionally, the CA must have WebTrust audits covering periods
no longer than one year in duration where each audit period must immediately start after the previous
period end with no gaps.
Amazon will post links to Subordinate CA certificates, CP, CPS, and audit options (if applicable) in its
repository.

4.2.3 Time to process certificate applications
The time required to process a certificate application shall not exceed the time to approve or reject theapplication.

144.3 Certificate issuance
4.3.1 CA actions during certificate issuanceAmazon confirms the source of a certificate request before issuance. Databases and CA processes occurring
during certificate issuance are protected from unauthorized modification. After issuance is complete, thecertificate is stored in a database and sent to the Subscriber.

4.3.2 Notification to subscriber by the CA of issuance of certificate
Amazon will deliver certificates within a reasonable time after issuance. Generally, Amazon delivers
certificates via email to the email address designated by the Subscriber, via a programmatic method such as anAPI, or via download from a website.

4.4 Certificate acceptance
4.4.1 Conduct constituting certificate acceptance
Subscribers are solely responsible for installing the issued certificate on the Subscriber’s computer or
hardware security module. Certificates are considered accepted on the earlier of• The Subscriber’s use of the certificate,• 30 days after the certificate’s issuance.

4.4.2 Publication of the certificate by the CA
Amazon publishes all CA certificates in its repository and publishes end entity certificates by delivering themto the Subscriber using email or an API.
Subordinate CA certificates are provided to relevant entities as part of the certificate chain.

4.4.3 Notification of certificate issuance by the CA to other entities
RAs may receive notification of a certificate’s issuance if the RA was involved in the issuance process.
Amazon may notify the public of the issuance of a certificate by adding it to one or more publicly accessible
Certificate Transparency (CT) Logs.

4.5 Key pair and certificate usage
4.5.1 Subscriber private key and certificate usage
Subscribers are contractually obligated to protect their Private Keys from unauthorized use or disclosure,
discontinue using a Private Key after expiration or revocation of the associated certificate, and use
Certificates in accordance with their intended purpose.

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4.5.2 Relying party public key and certificate usage
Relying Parties may only use software that is compliant with X.509, IETF RFCs, and other applicablestandards. Amazon does not warrant that any third party software will support or enforce the controls andrequirements found herein.
A Relying Party should use discretion when relying on a certificate and should consider the totality of thecircumstances and risk of loss prior to relying on a certificate. If the circumstances indicate that additional
assurances are required, the Relying Party must obtain such assurances before using the certificate. Any
warranties provided by Amazon are only valid if a Relying Party’s reliance was reasonable.
A Relying Party should rely on a digital signature or SSL/TLS handshake only if:
1. The digital signature or SSL/TLS session was created during the operational period of a valid
certificate and can be verified by referencing a valid certificate,
2. The certificate is not revoked and the Relying Party checked the revocation status of the certificate
prior to the certificate’s use by referring to the relevant CRLs or OCSP responses, and3. The certificate is being used for its intended purpose and in accordance with this CPS.
Before relying on a time stamp token, a Relying Party must:
1. Verify that the time stamp token has been correctly signed and that the Private Key used to sign thetime stamp token has not been compromised prior to the time of the verification,
2. Take into account any limitations on the usage of the time stamp token indicated by the time stamp
policy, and
3. Take into account any other precautions prescribed in this CPS or elsewhere.

4.6 Certificate renewal
Amazon treats all certificate renewal requests as applications for certificate issuance and follows the sameprocedures used when issuing a certificate.

4.6.1 Circumstance for certificate renewal
No stipulation.

4.6.2 Who may request renewal
See §4.1.1.

4.6.3 Processing certificate renewal requests
See §4.2.

4.6.4 Notification of new certificate issuance to subscriber
See §4.3.2.

16

4.6.5 Conduct constituting acceptance of a renewal certificate
See §4.4.1.

4.6.6 Publication of the renewal certificate by the CA
See §4.4.2.

4.6.7 Notification of certificate issuance by the CA to other entities
See §4.4.3.

4.7 Certificate re-key
Amazon treats all certificate re-key requests as applications for certificate issuance and follows the sameprocedures used when issuing a certificate.

4.7.1 Circumstance for certificate re-key
No stipulation.

4.7.2 Who may request certification of a new public key
See §4.1.1.

4.7.3 Processing certificate re-keying requests
See §4.2.

4.7.4 Notification of new certificate issuance to subscriber
See §4.3.2.

4.7.5 Conduct constituting acceptance of a re-keyed certificate
See §4.4.1.

4.7.6 Publication of the re-keyed certificate by the CA
See §4.4.2.

4.7.7 Notification of certificate issuance by the CA to other entities
See §4.4.3.

4.8 Certificate modification
Amazon treats all certificate modification requests as applications for certificate issuance and follows thesame procedures used when issuing a certificate.

174.8.1 Circumstance for certificate modification
No stipulation.

4.8.2 Who may request certificate modificationSee §4.1.1.

4.8.3 Processing certificate modification requests
See §4.2.

4.8.4 Notification of new certificate issuance to subscriber
See §4.3.2.

4.8.5 Conduct constituting acceptance of modified certificate
See §4.4.1.

4.8.6 Publication of the modified certificate by the CA
See §4.4.2.

4.8.7 Notification of certificate issuance by the CA to other entities
See §4.4.3.

4.9 Certificate revocation and suspension
Revocation of a certificate permanently ends the operational period of the certificate prior to the certificate
reaching the end of its stated validity period.

4.9.1 Circumstances for revocation
Amazon will revoke a certificate if the revocation request was made by either the organization or individualthat made the certificate application or by an entity with the legal jurisdiction and authority to request
revocation.
Amazon will follow the Amazon CP and revoke a certificate in accordance with §4.9.1.1 and §4.9.1.2 of the
Amazon CP.
Amazon always revokes a certificate if the binding between the Subject and the Subject’s Public Key in thecertificate is no longer valid or if an associated Private Key is compromised.
Amazon will revoke a cross certificate if the cross certified entity (including Amazon) no longer meets the
stipulations of the corresponding policies, as indicated by policy OIDs listed in the policy mapping extensionof the cross certificate.

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4.9.2 Who can request revocation
Any appropriately authorized party, such as a recognized representative of a Subscriber or cross-signed
partner, may request revocation of a certificate. Amazon may revoke a certificate without receiving a request
and without reason. Third parties may request certificate revocation for problems related to fraud, misuse,compromise, or non-compliance with the CP or CPS. Certificate revocation requests must identify the entity
requesting revocation and specify the reason for revocation.
Subscribers may request revocation of their own certificates by emailing aws-tsp-requests@amazon.com. All
reports need to include sufficient detail to identify the specific certificates to be revoked.

4.9.3 Procedure for revocation request
Amazon processes a revocation request as follows:
1. Amazon logs the identity of entity making the request or problem report and the reason for requesting
revocation. Amazon may also include its own reasons for revocation in the log.
2. Amazon may request confirmation of the revocation from a known administrator, where applicable,
via out of band communication (e.g., telephone, fax, etc.).
3. If the request is authenticated as originating from the Subscriber, Amazon revokes the certificate.
4. For requests from third parties, Amazon personnel begin investigating the request within 24 hours
after receipt and decide whether revocation is appropriate based on the following criteria:
a. The nature of the alleged problem,b. The number of reports received about a particular certificate or website,c. The identity of the complainants (for example, complaints from a law enforcement official thata web site is engaged in illegal activities have more weight than a complaint from a consumer
alleging they never received the goods they ordered), andd. Relevant legislation.
5. If Amazon determines that revocation is appropriate; Amazon personnel revoke the certificate andupdate the CRL.
Amazon maintains a continuous 24/7 ability to internally respond to any high priority revocation requests. If
appropriate, Amazon forwards complaints to law enforcement.
Instructions for requesting revocation are linked from the Repository.

4.9.4 Revocation request grace period
Subscribers are required to request revocation within one day after detecting the loss or compromise of thePrivate Key. Amazon may grant and extend revocation grace period on a case-by-case basis.

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4.9.5 Time within which CA must process the revocation request
Amazon will revoke a CA certificate within one hour after receiving clear instructions from the APPMA.
Other certificates are revoked as quickly as practical after validating the revocation request, generally within
the following time frames:
1. Certificate revocation requests for publicly trusted certificates are processed within 18 hours after
their receipt,
2. Revocation requests received two or more hours before CRL issuance are processed before the next
CRL is published, and
3. Revocation requests received within two hours of CRL issuance are processed before the following
CRL is published.

4.9.6 Revocation checking requirement for relying parties
Prior to relying on information listed in a certificate, a Relying Party must confirm the validity of eachcertificate in the certificate path in accordance with IETF PKIX standards, including checking for certificate
validity, issuer to subject name chaining, policy and key use constraints, and revocation status through CRLs
or OCSP responders identified in each certificate in the chain.

4.9.7 CRL issuance frequency (if applicable)
Amazon will update and reissue CRLs with a frequency greater than or equal to that required by the Amazon
CP.

4.9.8 Maximum latency for CRLs (if applicable)
CRLs for certificates issued to end entity Subscribers are posted automatically to the online repository within
a commercially reasonable time after generation. Irregular, interim, or emergency CRLs are typically posted
within four hours after generation and within 24 hours of determining of the occurrence of a key
compromise. Regularly scheduled CRLs are posted prior to the next Update field in the previously issued
CRL of the same scope.
OCSP responses are provided within a commercially reasonable time and no later than ten seconds after therequest is received, under normal operating conditions. For EV certificates, responses are able to be
downloaded in no more than three (3) seconds over an analog telephone line under normal network
conditions.

4.9.9 On-line revocation/status checking availability
Amazon makes certificate status information available via OCSP for all certificates it issues.

4.9.10 On-line revocation checking requirements
A relying party must confirm the validity of a certificate prior to relying on the certificate.
Amazon OCSP responders comply with the requirements of the Amazon CP.

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4.9.11 Other forms of revocation advertisements available
Amazon allows, but does not require, OCSP stapling.

4.9.12 Special requirements re key compromise
No stipulation.

4.9.13 Circumstances for suspension
Amazon does not suspend certificates.

4.9.14 Who can request suspension
Not applicable.

4.9.15 Procedure for suspension request
Not applicable.

4.9.16 Limits on suspension period
Not applicable.

4.10 Certificate status services
4.10.1 Operational characteristics
Certificate status information is available via CRL and OCSP responder. The serial number of a revokedcertificate remains on the CRL until one additional CRL is published after the end of the certificate’s validity
period, except for revoked EV Code Signing Certificates, which remain on the CRL for at least 365 days
following the certificate’s validity period. OCSP information for Subscriber certificates is updated at least
every four days. OCSP information for subordinate CA certificates is updated at least every 12 months andwithin 24 hours after revoking the certificate.

4.10.2 Service availability
Certificate status services are designed to be available 24x7.

4.10.3 Optional features
Not applicable.

4.11 End of subscription
A Subscriber’s subscription service ends if its certificate expires or is revoked or if the applicable Subscriber
Agreement expires without renewal.

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4.12 Key escrow and recovery
Amazon does not escrow private keys.

4.12.1 Key escrow and recovery policy and practices
Not applicable.

4.12.2 Session key encapsulation and recovery policy and practices
Not applicable.

5. FACILITY, MANAGEMENT, AND OPERATIONAL CONTROLS
5.1 Physical controls
5.1.1 Site location and construction
Certificate Manufacturing Facilities are located in the United States. Private keys for all CAs following thisCPS are exclusively located in the United States unless otherwise stated in the Repository. Physical barriers,
including solid walls that extend from real floor to real ceiling are in place to prevent unauthorized entry to
Certificate Manufacturing Facilities.

5.1.2 Physical accessPhysical access to Amazon PKI facilities is restricted to authorized Amazon employees, vendors, andcontractors who require access to execute their jobs. Amazon uses multi-factor authentication mechanisms
for access control as well as additional security mechanisms designed to ensure that only authorizedindividuals enter PKI facilities.

5.1.3 Power and air conditioning
Heating, ventilation, and air conditioning systems are designed to maintain environmental specifications
provided system vendors.

5.1.4 Water exposures
Amazon’s facilities are designed to protect CA systems from water exposure.

5.1.5 Fire prevention and protection
Amazon’s facilities are designed to provide fire suppression for the CA.

5.1.6 Media storage
Amazon’s facilities and processes are designed to protect media from accidental damage and authorized
physical access.

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5.1.7 Waste disposal
Storage media containing sensitive data is physically destroyed or securely overwritten prior to disposal orreuse. Printed documents containing sensitive data needing disposal are stored in locked shred bins which areperiodically collected and destroyed by a data destruction company.

5.1.8 Off-site backup
Amazon maintains copies of CA private keys and activation data at multiple locations for redundancy. All
copies are stored in a system or device validated as meeting FIPS 140 Level 3 to ensure that they are only
accessible by trusted personnel.

5.2 Procedural controls
5.2.1 Trusted roles
Personnel acting in trusted roles include CA, TSA, and RA system administration personnel, and personnel
involved with identity vetting and the issuance and revocation of certificates. The functions and duties
performed by persons in trusted roles are distributed so that one person alone cannot circumvent security
measures or subvert the security and trustworthiness of the PKI or TSA operations. All personnel in trusted
roles must be free from conflicts of interest that might prejudice the impartiality of the Amazon PKI’s
operations. A list of personnel appointed to trusted roles is maintained and reviewed annually.
PKI Executive
The Executive is responsible for overseeing all activities in the Amazon PKI, including appointment of
persons to all other roles. The PKI Executive is a member of the PKI Policy Management Authority but
cannot function in any other Trusted Role.
PKI Policy Management Authority Member
The APPMA is responsible for approving this CPS and certain other documents related to CAs in the
Amazon PKI. The APPMA approves the generation, revocation and suspension of CA certificates.
APPMA members cannot serve in any other Trusted Role (except for PKI Executive).
PKI Managers
Amazon PKI Managers are responsible for PKI Operations and CA documents, including theCertificate Policy, Certification Practice Statement, and this document. The PKI Manager cannot serve
as a PKI Security Officer.
PKI Security Officer
PKI Security Officers have a combination to the safe and/or PINs for the PED keys necessary to use
the HSMs.
PKI Engineers
PKI Engineers are responsible for CA systems development and operations.
Validation Specialists
Validation Specialists are responsible for the collection and review of information in support of acertificate application. Validation Specialists look for discrepancies or other details requiring further
explanation in the application and supporting information.
Internal Auditor

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Internal Auditors are responsible for overseeing internal compliance to determine if Amazon, an
Issuer CA, or RA is operating in accordance with this CPS or an RA Practices Statement. This may
include acting as Witness to ceremonies or holding credential or key required to initiate a ceremony.

5.2.2 Number of persons required per task
Amazon ensures that at least three people are required for CA key generation, CA signing key activation, andCA private key backup.

5.2.3 Identification and authentication for each role
All personnel are required to authenticate themselves to CA and supporting systems before they are allowed
access to systems necessary to perform their trusted roles.

5.2.4 Roles requiring separation of duties
The PKI Executive may not concurrently serve as Internal Auditor, PKI Engineer, or Validation Specialist.
Persons serving as Internal Auditors may not hold any other trusted role. Persons serving as members of the
PMA may not serve as PKI Engineer or Validation Specialist.
For the issuance of Extended Validation certificates, the same person may not serve as both System Operator
and Verification Operator.

5.3 Personnel controls
5.3.1 Qualifications, experience, and clearance requirements
The APPMA is responsible and accountable for Amazon PKI operations and ensures compliance with thisCPS and the CP. Amazon personnel and management practices provide reasonable assurance of thetrustworthiness and competence of its employees and of the satisfactory performance of their duties.
Management and operational support personnel involved in time stamp operations possess experience withinformation security and risk assessment and knowledge of time stamping technology, digital signaturetechnology, mechanisms for calibration of time stamping clocks with UTC, and security procedures. The
APPMA ensures that all individuals assigned to trusted roles have the experience, qualifications, andtrustworthiness required to perform their duties under this CPS.

5.3.2 Background check procedures
Amazon verifies the identity of each employee appointed to a trusted role and performs a background checkprior to allowing such person to act in a trusted role. Amazon requires each individual to appear in person
before a human resources employee whose responsibility it is to verify identity. The human resources
employee verifies the individual’s identity using government issued photo identification (e.g., passports and/or driver’s licenses reviewed pursuant to U.S. Citizenship and Immigration Services Form I 9, Employment
Eligibility Verification, or comparable procedure for the jurisdiction in which the individual’s identity is
being verified). Background checks include employment history, education, character references, social
security number, previous residences, driving records and criminal background. Checks of previous

24residences are over the past three years. All other checks are for the previous five years. The highest education
degree obtained is verified regardless of the date awarded. Background checks are refreshed at least every ten
years.

5.3.3 Training requirements
Amazon provides suitable training to all staff before they take on a Trusted Role should they not already havethe complete skill-set required for that role.
Training of personnel is undertaken via a mentoring process involving senior members of the team to which
they are attached.
Validation Specialists are trained in Amazon’s validation and verification policies and procedures.

5.3.4 Retraining frequency and requirements
Personnel in Trusted Roles have additional training when changes in industry standards or changes inAmazon’s operations require it.
Amazon provides refresher training and informational updates sufficient to ensure that Trusted Personnel
retain the requisite degree of expertise.

5.3.5 Job rotation frequency and sequence
No stipulation.

5.3.6 Sanctions for unauthorized actions
Amazon employees and agents failing to comply with this CPS, whether through negligence or malicious
intent, are subject to administrative or disciplinary actions, including termination of employment or agency
and criminal sanctions. If a person in a trusted role is cited by management for unauthorized or inappropriate
actions, the person will be immediately removed from the trusted role pending management review. After
management has reviewed and discussed the incident with the employee involved, management may reassignthat employee to a non-trusted role or dismiss the individual from employment as appropriate.

5.3.7 Independent contractor requirements
Independent contractors who are assigned to perform trusted roles are subject to the duties and requirements
specified for such roles as specified in 5.3 Personnel controls and are subject to sanctions specified in 5.3.6
Sanctions for Unauthorized Actions.

5.3.8 Documentation supplied to personnel
Personnel in trusted roles are provided with the documentation necessary to perform their duties, including a
copy of the CP, this CPS, EV Guidelines, and other technical and operational documentation needed tomaintain the integrity of Amazon CA operations.

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5.4 Audit logging procedures
5.4.1 Types of events recorded
Audit log files are be generated for all events relating to the security and services of the CA. Where possible,
the security audit logs are be automatically generated. Where this is not possible, a logbook, paper form, orother physical mechanism are be used. All security audit logs, both electronic and non-electronic, shall be
retained and made available during compliance audits.
Amazon ensures all events relating to the lifecycle of Certificates are logged in a manner to ensure thetraceability to a person in a trusted role for any action required for CA services. At a minimum, each audit
record includes the following (either recorded automatically or manually) elements:• the type of event;• the date and time the event occurred;• success or failure where appropriate;• the identity of the entity and/or operator that caused the event;• the identity to which the event was targeted; and• the cause of the event.

5.4.2 Frequency of processing log
Logs are archived by the system administrator within 7 days of event activity. CA management reviews logs
in the audit log repository at least every 93 days.

5.4.3 Retention period for audit log
Audit logs are retained for at least seven years and will be made available to the Amazon external independent
auditor upon request.

5.4.4 Protection of audit log
Production and archived logical and physical audit logs are protected using a combination of physical andlogical access controls.

5.4.5 Audit log backup procedures
Amazon makes regular backup copies of audit logs and audit log summaries and sends a copy of the audit log
off-site on a monthly basis.

5.4.6 Audit collection system (internal vs. external)
Automatic audit data is generated and recorded at the application, network, and operating system level. If an
automated audit system fails and the integrity of the system or confidentiality of the information protected by
the system is at risk, Amazon Administrators will consider suspending its operation until the problem isremedied. Manually generated audit data is recorded by authorized Amazon personnel.

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5.4.7 Notification to event-causing subject
No stipulation.

5.4.8 Vulnerability assessments
Amazon performs a vulnerability scan at least once a quarter on Certificate System IP addresses. Amazon will
perform a vulnerability scan after any system or network changes that Amazon determines are significant andwithin one week of receiving a request from the CA/Browser Forum. Amazon will undergo a Penetration
Test on Certificate Systems on at least an annual basis and after infrastructure or application upgrades that
Amazon determines are significant.
Amazon records will be maintained in a manner reasonably sufficient to demonstrate that each Vulnerability
Scan and Penetration Test was performed by a person or entity with the skills, tools, proficiency, code of
ethics, and independence necessary to provide a reliable Vulnerability Scan or Penetration Test.

5.5 Records archival
Amazon complies with all record retention policies that apply by law. Amazon includes reasonably sufficientdetail in its archived records to show that a certificate or time-stamp token was issued in accordance with thisCPS.

5.5.1 Types of records archived
Amazon backs up both application and system data. Amazon may archive the following information:• audit data, as specified in section 5.4 of this CPS;
• certificate application information;• documentation supporting a Certificate application; and• certificate lifecycle information.

5.5.2 Retention period for archive
Amazon retains the records of Amazon digital certificates and the associated documentation for a term of notless than 7 years, or as necessary to comply with applicable laws.

5.5.3 Protection of archive
Archive records are stored at a secure off-site location and are maintained in a manner that prevents
unauthorized modification, substitution, or destruction. Archives are not released except as allowed by the
APPMA or as required by law. Amazon maintains any software application required to process the archive
data until the data is either destroyed or transferred to a newer medium.
If Amazon needs to transfer any media to a different archive site or equipment, Amazon will maintain botharchived locations and/or pieces of equipment until the transfer are complete. All transfers to new archives
will occur in a secure manner.

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5.5.4 Archive backup procedures
Amazon maintains backup copies of its archived records at a location distinct from either Certificate
Manufacturing Facility.

5.5.5 Requirements for time-stamping of records
Amazon time-stamps archived records with system time (non-cryptographic method) as they are created.
Online systems are synchronized with a third party time source using automated means. Air-gapped systems
have their time manually set. Manual journal entries have a manually entered date and time.

5.5.6 Archive collection system (internal or external)
Archive information is collected internally by Amazon.

5.5.7 Procedures to obtain and verify archive information
No stipulation.

5.6 Key changeover
Key changeover procedures enable the smooth transition from expiring CA certificates to new CA
certificates. Towards the end of a CA Private Key’s lifetime, Amazon ceases using the expiring CA Private Keyto sign certificates and uses the expiring Private Key only to sign CRLs and OCSP responder certificates. A
new CA signing key pair is commissioned and all subsequently issued certificates and CRLs are signed with
the new private signing key. Both the old and the new key pairs may be concurrently active. This key
changeover process helps minimize any adverse effects from CA certificate expiration. The corresponding
new CA Public Key certificate is provided to Subscribers and Relying Parties through the delivery methods
detailed in 6.1.4 CA Public Key Delivery to Relying Parties. Where Amazon has cross-certified another CAthat is in the process of a key rollover, Amazon obtains a new CA Public Key or new CA certificate from theother CA and distributes a new CA cross certificate following the procedures described above.

5.7 Compromise and disaster recovery
5.7.1 Incident and compromise handling procedures
Amazon maintains incident response procedures to guide personnel in response to security incidents, natural
disasters, and similar events that may give rise to system compromise. Amazon reviews, tests, and updates its
incident response plans and procedures on at least an annual basis.

5.7.2 Computing resources, software, and/or data are corrupted
If Amazon discovers that any of its computing resources, software, or data operations have been
compromised, Amazon assesses the threats and risks that the compromise presents to the integrity or securityof its operations or those of affected parties. If Amazon determines that a continued operation could pose asignificant risk to Relying Parties or Subscribers, Amazon suspends such operation until it determines thatthe risk is mitigated.

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5.7.3 Entity private key compromise procedures
In the event a CA Private Key is Compromised, lost, destroyed or suspected to be Compromised, Amazon
will, after investigation of the problem, decide if the CA Certificate should be revoked. If so, then all the
Subscribers who have currently unrevoked unexpired certificates will be notified at the earliest feasible
opportunity. A new CA Key Pair will be generated or an alternative existing CA hierarchy will be used tocreate new Subscriber Certificates.
If Root CA private keys compromised, Amazon will inform browser vendors of the compromise and best
estimate of the date of compromise.

5.7.4 Business continuity capabilities after a disaster
Amazon systems are redundantly configured at its primary facility and are mirrored at a separate,
geographically diverse location for failover in the event of a disaster. If a disaster causes Amazon PKI
operations to become inoperative at one site, Amazon will re-initiate its operations at its alternative site.

5.8 CA or RA termination
Before terminating its CA or TSA activities, Amazon will:
1. Provide notice and information about the termination by sending notice by email to its customers
with unrevoked unexpired certificates, Application Software Vendors, and any cross certifying entities
and by posting such information on Amazon web site; and2. Transfer all responsibilities to a qualified successor entity.
If a qualified successor entity does not exist, Amazon will:
1. Transfer those functions capable of being transferred to a reliable third party and arrange to preserve
all relevant records with a reliable third party or a government, regulatory, or legal body withappropriate authority;
2. Revoke all certificates that are still un revoked or un expired on a date as specified in the notice andpublish final CRLs;
3. Destroy all Private Keys; and4. Make other necessary arrangements that are in accordance with this CPS.

6. TECHNICAL SECURITY CONTROLS
6.1 Key pair generation and installation
6.1.1 Key pair generation
Amazon CA key pairs are generated on hardware that meets the requirements of §6.2.1. They are generated
during a ceremony that meets requirements of the Amazon CP.
Subscriber key pairs are generated by the Subscriber.

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6.1.2 Private key delivery to subscriber
Amazon does not generate keys for Subscribers and does not distribute Integrated Circuit Cards tosubscribers

6.1.3 Public key delivery to certificate issuer
Subscribers generate key pairs and submit the Public Key to Amazon in a CSR as part of the certificate
request process. The Subscriber’s signature on the request is authenticated prior to issuing the certificate.

6.1.4 CA public key delivery to relying parties
Amazon Public Keys are provided to Relying Parties as trust anchors in commercial browsers and operating
system root stores and/or as roots signed by other CAs. All accreditation authorities supporting Amazon
certificates and all application software providers are permitted to redistribute Amazon root anchors.
Amazon may also distribute Public Keys that are part of an updated signature-Key Pair as a self-signed
certificate, as a new CA certificate, or in a key roll over certificate. Relying Parties may obtain Amazon selfsigned CA certificates from the Amazon web site.

6.1.5 Key sizes
Amazon CAs use RSA and elliptic curve keys. All RSA keys are 2048-bits or larger and all elliptic curve keys
are on one of three NIST curves (P-256, P-384, or P-521).

6.1.6 Public key parameters generation and quality checking
Amazon uses a HSM device that conforms to FIPS 186 2 and provides random number generation and onboard generation of up to 4096 bit RSA Public Keys and a wide range of ECC curves.

6.1.7 Key usage purposes (as per X.509 v3 key usage field)
Amazon includes Key Usage and Extended Key Usage fields in certificates as defined in the certificate profile.

6.2 Private Key Protection and Cryptographic Module Engineering Controls
6.2.1 Cryptographic module standards and controls
Amazon generates and stores all Private Keys used for certificate signing in cryptographic modules that meetat least one of the following:• Certified to FIPS 140-1 or 140-2, Level 3 (or higher)• Certified to ISO/IEC 19790, Level 3 (or higher)30• Certified to EAL4 (or higher) of the CWA 14169 or EN 14169 Protection Profile under the Common
Criteria (ISO/IEC 15408) framework
Subscribers must store Private Keys used for Extended Validation Code Signing and Augmented Clientcertificates in cryptographic modules that meet at least one of the following:• Certified to FIPS 140-1 or 140-2, Level 2 or higher• Certified to ISO/IEC 19790, Level 2 or higher• Certified to EAL4 of the CWA 14169 or EN 14169 Protection Profile under the Common Criteria(ISO/IEC 15408) framework; or• Certified as a Secure Signature Creation Device (SSCD) by an EU government entity

6.2.2 Private key (n out of m) multi-person control
Amazon authentication mechanisms are protected securely when not in use and may only be accessed byactions of multiple trusted persons.
Backups of CA Private Keys are securely stored off site and require at least two-person access. Re activationof a backed up CA Private Key (unwrapping) requires the same security and multi person control as when
performing other sensitive CA Private Key operations.

6.2.3 Private key escrow
Amazon does not escrow its signature keys and does not provide Subscriber key escrow.

6.2.4 Private key backup
If required for business continuity, Amazon backs up Private Keys under the same multi-person control as theoriginal keys.

6.2.5 Private key archival
Amazon does not archive private keys.

6.2.6 Private key transfer into or from a cryptographic module
All keys must be generated by and in a cryptographic module. Private Keys are exported from thecryptographic module only for backup purposes. The Private Keys are encrypted when transferred out of themodule and never exist in plaintext form.

6.2.7 Private key storage on cryptographic module
Amazon Private Keys are generated and stored inside cryptographic modules which meet the requirements of§6.2.1.

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6.2.8 Method of activating private key
Amazon Private Keys are activated according to the specifications of the cryptographic module manufacturer.
Activation data entry is protected from disclosure. Subscribers are solely responsible for protecting their
Private Keys. Subscribers should use a strong password or equivalent authentication method to prevent
unauthorized access or use of the Subscriber’s Private Key.

6.2.9 Method of deactivating private key
Amazon Private Keys are deactivated via logout procedures on the applicable HSM device when not in use.
Root Private Keys are further deactivated by removing them entirely from the storage partition on the HSM
device. Amazon never leaves its HSM devices in an active unlocked or unattended state.

6.2.10 Method of destroying private key
Amazon personnel, acting in trusted roles, destroy CA, RA, and status server Private Keys when no longer
needed. Amazon may destroy a Private Key by deleting it from all known storage partitions. Amazon also
zeroizes the HSM device and associated backup tokens according to the specifications of the hardware
manufacturer. If the zeroization or re initialization procedure fails, Amazon will crush, shred, and/orincinerate the device in a manner that destroys the ability to extract any Private Key.

6.2.11 Cryptographic Module RatingSee §6.2.1.

6.3 Other aspects of key pair management
6.3.1 Public key archival
Amazon archives copies of Public Keys as specified in §5.5.

6.3.2 Certificate operational periods and key pair usage periods
The lifetime of Amazon’s Root CA certificates is as set out in section 1.1. Key pairs in Amazon root
certificates have the same term as the certificate validity period. Certificates signed by the CA have a validity
period that terminates on or before the end of the validity period of the CA.

6.4 Activation data
6.4.1 Activation data generation and installation
Generation and use of CA activation data used to activate CA Private Keys are made during a key ceremony.
Activation data is either generated automatically by the appropriate HSM or in such a way that meets thesame needs. It is then delivered to a holder of a share of the key who is a person in a trusted role. The delivery
method maintains the confidentiality and the integrity of the activation data.

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6.4.2 Activation data protection
CA activation data is protected from disclosure through a combination of cryptographic and physical access
control mechanisms.

6.4.3 Other aspects of activation data
No stipulation.

6.5 Computer security controls
6.5.1 Specific computer security technical requirements
Amazon PKI systems maintaining CA software and data files are secure from unauthorized access. In
addition, access to production servers is limited to those individuals with a valid business reason for suchaccess.
The Amazon PKI production network is separate from other components. This separation prevents network
access except through specific application processes. Amazon has access control technologies in place toprotect the production network from unauthorized internal and external access and to limit network
activities accessing production systems.

6.5.2 Computer security rating
No stipulation.

6.6 Life cycle technical controls
6.6.1 System development controls
Amazon has mechanisms in place to control and monitor the acquisition and development of its CA systems.
Change requests require the approval of at least one administrator who is different from the person
submitting the request. Amazon only installs software on CA systems if the software is part of the CA’s
operation. CA hardware and software are dedicated to performing operations of the CA.
Vendors are selected based on their reputation in the market, ability to deliver quality product, and likelihoodof remaining viable in the future. Management is involved in the vendor selection and purchase decision
process. Non-PKI hardware and software is usually purchased without identifying the purpose for which thecomponent will be used. All hardware and software are shipped under standard conditions to ensure deliveryof the component directly to a trusted employee who ensures that the equipment is installed without
opportunity for tampering.
Some of the PKI software components used by Amazon are developed in-house or by consultants using
standard software development methodologies. All such software is designed and developed in a controlledenvironment and subjected to quality assurance review. Other software is purchased commercial off-theshelf. Quality assurance is maintained throughout the process through testing and documentation or bypurchasing from trusted vendors as discussed above.

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Updates of equipment and software are purchased or developed in the same manner as the original
equipment or software and are installed and tested by trusted and trained personnel. All hardware andsoftware essential to Amazon operations is scanned for malicious code on first use and periodicallythereafter.

6.6.2 Security management controls
Amazon has mechanisms in place to control and monitor the security-related configurations of its CA
systems. When loading software onto a CA system, Amazon verifies that the software is the correct version
and is supplied by the vendor free of any modifications. Amazon verifies the integrity of software used with
its CA processes at least once per week.

6.6.3 Life cycle security controls
No stipulation.

6.7 Network security controls
Amazon has implemented reasonable safeguards and controls to prevent unauthorized access to the various
systems and devices that comprise the CA infrastructure and to various degrees depending on the sensitivityof the function. Root CA private keys are kept offline and protected by various means.

6.8 Time-stamping
See §5.5.5.

7. CERTIFICATE, CRL, AND OCSP PROFILES
Amazon uses the ITU X.509, version 3 standard to construct digital certificates for use within the Amazon
PKI. Amazon adds certain certificate extensions to the basic certificate structure for the purposes intended by
X.509v3 as per Amendment 1 to ISO/IEC 9594-8, 1995.

7.1 Certificate profile
7.1.1 Version number(s)All certificates are X.509 version 3 certificates.

7.1.2 Certificate extensions
See Amazon Certificate Profiles appendix.

7.1.3 Algorithm object identifiers
See Amazon Certificate Profiles appendix.

34

7.1.4 Name forms
Each certificate includes a unique positive serial number that is never reused. Optional subfields in the subjectof an SSL Certificate must either contain information verified by Amazon or be left empty. SSL Certificates
cannot contain metadata such as ‘.’, ‘-‘ and ‘ ‘ characters or any other indication that the field is not applicable.
Amazon logically restricts OU fields from containing Subscriber information that has not been verified as
specified in 3 Identification and Authentication.
The distinguished name for each Certificate type is set forth in Amazon certificate profiles appendix. The
contents of the fields in EV Certificates must meet the requirements in Section 8.1 of the EV Guidelines.

7.1.5 Name constraints
No stipulation.

7.1.6 Certificate policy object identifier
Certificates that are issued under the Amazon PKI and are compliant with the CA/Browser Forum Baseline
Requirements may include the 1.3.187.1 object identifier in their policy list.
Certificates that are issued under the Amazon PKI and are complaint with the CA/Browser Forum Extended
Validation Guidelines may include the 1.3.187.1.1 object identifier in the policy list.

7.1.7 Usage of Policy Constraints extension
Not applicable.

7.1.8 Policy qualifiers syntax and semantics
Not applicable.

7.1.9 Processing semantics for the critical Certificate Policies extension
Not applicable.

7.2 CRL profile
7.2.1 Version number(s)Amazon issues version 2 CRLs.

7.2.2 CRL and CRL entry extensions
Field

Value

CRL Number

Never repeated monotonically increasing integer

Authority Key Identifier Same as the Authority Key Identifier listed in the certificate
Invalidity Date

Optional date in UTC format

35

FieldValue

Reason Code

Optional reason for revocation

7.3 OCSP profile
7.3.1 Version number(s)Amazon OCSP responders conform to version 1 as defined in RFC 6960. Amazon OCSP responders may
decline to respond to messages that do not comply with RFC 5019. Specifically, Amazon OCSP responders
may not include a nonce in the reply even if a nonce is provided in the request.

7.3.2 OCSP extensions
No stipulations.

8. COMPLIANCE AUDIT AND OTHER ASSESSMENTS
The practices in this CPS are designed to meet or exceed the requirements of generally accepted industry
standards, including the latest version of the EV Guidelines and the AICPA/CICA WebTrust Program for
Certification Authorities, ANS X9.79/ISO 21188 PKI Practices and Policy Framework (“CA WebTrust/ISO
21188”).

8.1 Frequency or circumstances of assessment
The WebTrust for CAs audit mandates that the period during which a CA issues Certificates be divided into
an unbroken sequence of audit periods. An audit period must not exceed one year in duration.

8.2 Identity/qualifications of assessor
Amazon receives an annual audit by an independent external auditor to assess Amazon compliance with this
CPS, any applicable CPs, and the CA WebTrust/ISO 21188 and WebTrust EV Program criteria. The audit
covers Amazon operated RA systems, Sub CAs, and OCSP Responders.
WebTrust auditors must meet the requirements of Section 14.1.14 of the EV Guidelines. Specifically:
1. Qualifications and experience: Auditing must be the auditor’s primary business function. The
individual or at least one member of the audit group must be qualified as a Certified Information
Systems Auditor, an AICPA Certified Information Technology Professional, a Certified Internal
Auditor, or have another recognized information security auditing credential. Auditors must be
subject to disciplinary action by its licensing body.
2. Expertise: The individual or group must be trained and skilled in the auditing of secure information
systems and be familiar with Public Key infrastructures, certification systems, and Internet security
issues.
3. Rules and standards: The auditor must conform to applicable standards, rules, and best practices
promulgated by the American Institute of Certified Public Accountants (AICPA), the Canadian
Institute of Chartered Accountants (CICA), the Institute of Chartered Accountants of England & Wales(ICAEW), the International Accounting Standards adopted by the European Commission (IAS),
Information Systems Audit and Control Association (ISACA), the Institute of Internal Auditors (IIA),
or another qualified auditing standards body.

36

4. Reputation: The firm must have a reputation for conducting its auditing business competently andcorrectly.
5. Insurance: EV auditors must maintain Professional Liability/Errors and Omissions Insurance, with
policy limits of at least $1 million in coverage.

8.3 Assessor’s relationship to assessed entity
Amazon’s WebTrust auditor does not have a financial interest, business relationship, or course of dealing that
could foreseeably create a significant bias for or against Amazon.

8.4 Topics covered by assessment
The audit covers Amazon business practices disclosure, the integrity of Amazon PKI operations, and Amazon
compliance with the EV Guidelines. The audit verifies that Amazon is compliant with the CP and this CPS.

8.5 Actions taken as a result of deficiency
If an audit reports a material noncompliance with applicable law, this CPS, the CP, or any other contractual
obligations related to Amazon, then (1) the auditor will document the discrepancy, (2) the auditor willpromptly notify Amazon, and (3) Amazon will develop a plan to cure the noncompliance. Amazon will submit
the plan to the APPMA for approval and to third parties if required by law. The APPMA may require
additional action if necessary to rectify any significant issues created by the non- compliance, including
requiring revocation of affected certificates.

8.6 Communication of results
The results of each audit are reported to the APPMA, to the public and to any third party entities which areentitled by law, regulation, or agreement to receive a copy of the audit results. On an annual basis, Amazon
submits a report of its audit compliance to various parties, such as Mozilla, Microsoft, CA licensing bodies,etc. Amazon is not required to make publicly available any general audit finding that does not impact theoverall audit opinion.

8.7 Self-Audits
On at least a quarterly basis, Amazon performs regular internal audits against a randomly selected sample ofat least the greater of 1 certificate or three percent of the certificates issued since the last internal audit.
Internal audits on EV Certificates are performed in accordance with section 14.1.2 of the EV Guidelines.

9. OTHER BUSINESS AND LEGAL MATTERS
9.1 Fees
9.1.1 Certificate issuance or renewal fees
Amazon may charge Subscribers for certificate issuance and renewal.

9.1.2 Certificate access fees
No stipulation.

37

9.1.3 Revocation or status information access fees
Amazon does not charge a certificate revocation fee or a fee for checking the validity status of an issued
certificate using a CRL. Amazon may charge a fee for providing certificate status information via OCSP.

9.1.4 Fees for other services
Amazon does not charge Subscribers for revocation.

9.1.5 Refund policy
No stipulation.

9.2 Financial responsibility
9.2.1 Insurance coverage
Amazon maintains insurance or self-insures in accordance with Section 9.2.1 of the CP.

9.2.2 Other assets
No stipulation.

9.2.3 Insurance or warranty coverage for end-entities
No stipulation.

9.3 Confidentiality of business information
9.3.1 Scope of confidential information
The following information is considered confidential information of Amazon and is protected against
disclosure using a reasonable degree of care:
1. Private Keys;
2. Activation data used to access Private Keys or to gain access to the CA system;
3. Business continuity, incident response, contingency, and disaster recovery plans;
4. Other security practices used to protect the confidentiality, integrity, or availability of information;
5. Information held by Amazon as private information in accordance with 9.3 Confidentiality ofBusiness Information;
6. Audit logs and archive records; and38

7. Transaction records, financial audit records, and external or internal audit trail records and any audit
reports (with the exception of an auditor’s letter confirming the effectiveness of the controls set forthin this CPS).

9.3.2 Information not within the scope of confidential information
Certificates and revocation data are considered public information. Amazon reserves the right to publish a
CRL as may be indicated.

9.3.3 Responsibility to protect confidential information
Amazon employees, agents, and contractors are responsible for protecting confidential information and arebound by Amazon’s policies with respect to the treatment of confidential information or are contractually
obligated to do so. Employees receive training on how to handle confidential information.

9.4 Privacy of personal information
9.4.1 Privacy plan
Amazon follows the privacy policy posted on its website when handling personal information.

9.4.2 Information treated as private
Amazon treats all personal information about an individual that is not publicly available in the contents of acertificate or CRL as private information. Amazon protects private information using appropriate safeguards
and a reasonable degree of care.

9.4.3 Information not deemed private
Certificates and revocation data are not private information.

9.4.4 Responsibility to protect private information
Amazon employees and contractors are subject to policies or contractual obligations requiring such
employees and contractors to comply with the Amazon Privacy Policy or contractual obligations at least as
protective of private information as the Amazon Privacy Policy.

9.4.5 Notice and consent to use private information
Amazon follows the privacy policy posted on its website when using personal information.

9.4.6 Disclosure pursuant to judicial or administrative process
Amazon will not disclose Subject private information unless required to do so to comply with a legally valid
and binding order, such as a subpoena or a court order.

9.4.7 Other information disclosure circumstances
No stipulation.

399.5 Intellectual property rights
Amazon and/or its business partners own the intellectual property rights in Amazon’s services, including thecertificates, trademarks used in providing the services, and this CPS. Certificate and revocation information
are the property of Amazon. Amazon grants permission to reproduce and distribute certificates on a nonexclusive and royalty-free basis, provided that they are reproduced and distributed in full. Private Keys andPublic Keys remain the property of the Subscribers who rightfully hold them.

9.6 Representations and warranties
9.6.1 CA representations and warranties
Except as expressly stated in this CPS or in a separate agreement with a Subscriber, Amazon does not makeany representations or warranties regarding its products or services. Amazon represents and warrants, to theextent specified in this CPS, that:
1. Amazon complies, in all material aspects, with the CP and this CPS,
2. Amazon publishes and updates CRLs and OCSP responses on a regular basis,
3. All certificates issued under this CPS will be verified in accordance with this CPS and meet theminimum requirements found herein and in the Baseline Requirements, and
4. Amazon will maintain a repository of public information on its website.
For EV Certificates, Amazon warrants to Subscribers, Subjects, Application Software Vendors that distribute
Amazon root certificates, and Relying Parties that use an Amazon certificate while the certificate is valid that
Amazon followed the EV Guidelines in all material respects when verifying information and issuing EV
Certificates.
This foregoing warranty is limited solely to Amazon compliance with the EV Guidelines (e.g., Amazon may
rely on erroneous information provided in an attorney’s opinion or accountant’s letter that is checked inaccordance with the EV Guidelines).

9.6.2 RA representations and warranties
Each RA represents and warrants that:
1. The RA’s certificate issuance and management services conform to the Amazon CP and this CPS,
2. Information provided by the RA does not contain any false or misleading information,
3. Translations performed by the RA are an accurate translation of the original information, and
4. All certificates requested by the RA meet the requirements of this CPS.
Amazon’s agreement with the RA may contain additional representations and warranties.

9.6.3 Subscriber representations and warranties
Prior to issuance of a certificate, Amazon confirms that either:
1. the applicant has agreed to the Subscriber Agreement or
2. the applicant is an employee or agent of Amazon or an Affiliate of Amazon40

At least once every 12 months, the CA confirms that an authorized representative of Amazon has agreed to
the Terms of Use.
Subscribers represent and warrant that:
1. each digital signature created using the Private Key corresponding to the Public Key listed in thecertificate has been accepted and has not expired or been revoked at the time the digital signature iscreated;2. the Subscriber, or someone explicitly authorized by the Subscriber, have been and remain the only
person(s) in possession of Subscriber’s Private Key and all materials and information protecting
Subscriber’s Private Key, and no unauthorized person has had or will have access to such materials andinformation;
3. All material information Subscriber provides to the CA in Subscriber’s certificate application or
related to the issuance of a certificate is accurate, complete and up to date; and4. Subscriber’s certificates is and will be used in compliance with all applicable laws and in accordancewith this CPS, any subscriber agreement between Subscriber and the CA and any applicable standards,
including, without limitation, the EV Guidelines, as an end user and not as a CA to issue certificates,
certificate revocation lists, or otherwise.
The Subscriber Agreement between the Subscriber and Amazon may include additional representations andwarranties.

9.6.4 Relying party representations and warranties
Each Relying Party represents and warrants that, prior to relying on an Amazon certificate, it:
1. Obtained sufficient knowledge on the use of digital certificates and PKI,
2. Studied the applicable limitations on the usage of certificates and agrees to Amazon’s limitations on its
liability related to the use of certificates,
3. Has read, understands, and agrees to this CPS,
4. Verified both the Amazon certificate and the certificates in the certificate chain using the relevant CRL
or OCSP,
5. Will not use an Amazon certificate if the certificate has expired or been revoked, and
6. Will take all reasonable steps to minimize the risk associated with relying on a digital signature,including only relying on an Amazon certificate after considering:a. Applicable law and the legal requirements for identification of a party, protection of theconfidentiality or privacy of information, and enforceability of the transaction; b. The intended use of
the certificate as listed in the certificate or this CPS, c. The data listed in the certificate, d. The
economic value of the transaction or communication, e. The potential loss or damage that would becaused by an erroneous identification or a loss of confidentiality or privacy of information in theapplication, transaction, or communication, f. The Relying Party’s previous course of dealing with the
Subscriber, g. The Relying Party’s understanding of trade, including experience with computer-based
methods of trade, and h. Any other indicia of reliability or unreliability pertaining to the Subscriber
and/or the application, communication, or transaction.
Any unauthorized reliance on a certificate is at a party’s own risk.

41

9.6.5 Representations and warranties of other participants
No Stipulation.

9.7 Disclaimers of warranties
AMAZON’S SERVICE OFFERINGS IN CONNECTION WITH THIS CPS ARE PROVIDED “AS IS.” WE
AND OUR AFFILIATES AND LICENSORS MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY
KIND, WHETHER EXPRESS, IMPLIED, STATUTORY OR OTHERWISE REGARDING THE SERVICE
OFFERINGS OR ANY THIRD PARTY CONTENT, INCLUDING ANY WARRANTY THAT THE SERVICE
OFFERINGS OR THIRD PARTY CONTENT WILL BE UNINTERRUPTED, ERROR FREE OR FREE OF
HARMFUL COMPONENTS, OR THAT ANY CONTENT, WILL BE SECURE OR NOT OTHERWISE
LOST OR DAMAGED. EXCEPT TO THE EXTENT PROHIBITED BY LAW, WE AND OUR AFFILIATES
AND LICENSORS DISCLAIM ALL WARRANTIES, INCLUDING ANY IMPLIED WARRANTIES OF
MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, NONINFRINGEMENT, OR QUIET ENJOYMENT, AND ANY WARRANTIES ARISING OUT OF ANY
COURSE OF DEALING OR USAGE OF TRADE.

9.8 Limitations of liability
WE AND OUR AFFILIATES OR LICENSORS WILL NOT BE LIABLE TO YOU FOR ANY DIRECT,INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES (INCLUDINGDAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, OR DATA), EVEN IF A PARTY HAS BEEN
ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. FURTHER, NEITHER WE NOR ANY OF OUR
AFFILIATES OR LICENSORS WILL BE RESPONSIBLE FOR ANY COMPENSATION,REIMBURSEMENT, OR DAMAGES ARISING IN CONNECTION WITH: (A) YOUR INABILITY TO USE
A CERTIFICATE, INCLUDING AS A RESULT OF ANY (I) TERMINATION OR SUSPENSION OF THISCPS OR REVOCATION OF A CERTIFICATE, (II) OUR DISCONTINUATION OF ANY OR ALL SERVICE
OFFERINGS IN CONNECTION WITH THIS CPS, OR, (III) ANY UNANTICIPATED OR
UNSCHEDULED DOWNTIME OF ALL OR A PORTION OF CA SERVICES FOR ANY REASON,
INCLUDING AS A RESULT OF POWER OUTAGES, SYSTEM FAILURES OR OTHER INTERRUPTIONS;(B) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES; (C) ANY
INVESTMENTS, EXPENDITURES, OR COMMITMENTS BY YOU IN CONNECTION WITH THIS CPS
OR YOUR USE OF OR ACCESS TO AMAZON’S CA SERVICE OFFERINGS; OR (D) ANY
UNAUTHORIZED ACCESS TO, ALTERATION OF, OR THE DELETION, DESTRUCTION, DAMAGE,
LOSS OR FAILURE TO STORE ANY OF YOUR CONTENT OR OTHER DATA. IN ANY CASE, OUR AND
OUR AFFILIATES’ AND LICENSORS’ AGGREGATE LIABILITY IN CONNECTION WITH THIS CPS
AND ALL CERTIFICATES ISSUED HEREUNDER, IS LIMITED TO $500; PROVIDED, HOWEVER, THAT

42

FOR ANY EV CERTIFICATE ISSUED UNDER THIS CPS, OUR AND OUR AFFILIATES’ AND
LICENSORS’ AGGREGATE LIABILITY IS LIMITED TO $2,000 PER SUBSCRIBER OR RELYING PARTYPER EV CERTIFICATE.

9.9 Indemnities
Indemnification by Amazon
Amazon shall indemnify each Application Software Vendor against any damage or loss suffered by an
Application Software Vendor related to or arising out of any third party allegation, claim, lawsuit, or
proceeding (a “Claim”) to the extent such Claim is based on an EV Certificate issued by Amazon except where
the claim, damage, or loss suffered by the Application Software Vendor was directly caused by the Application
Software Vendor’s software displaying either (1) a valid and trustworthy EV Certificate as not valid ortrustworthy or (2) displaying as trustworthy (i) an EV Certificate that has expired or (ii) a revoked EV
Certificate where the revocation status is available online but the Application Software Vendor’s software
failed to check or ignored the status.
In connection with any Claim described in the foregoing paragraph, the indemnified party will: (a) give
Amazon prompt written notice of the Claim (provided that any delay in notification will not relieve Amazonof its indemnity obligations except to the extent that the delay impairs its ability to defend); (b) cooperatereasonably with Amazon (at Amazon’s expense) in connection with the defense and settlement of the Claim;and (c) permit Amazon to control the defense and settlement of the Claim, provided that Amazon may notsettle the Claim without the indemnified party’s prior written consent (which will not be unreasonably
withheld or delayed), and provided further that the indemnified party (at its cost) may participate in the
defense and settlement of the Claim with counsel of its own choosing. Amazon’s duty to indemnify under thisSection 9.9 will be independent from its other obligations under this Agreement.

Indemnification by Subscribers
To the extent permitted by law, each Subscriber shall indemnify Amazon, its partners, and any cross-signed
entities, and their respective directors, officers, employees, agents, and contractors against any loss, damage,or expense, including reasonable attorney’s fees, related to (i) any misrepresentation or omission by
Subscriber, regardless of whether the misrepresentation or omission was intentional or unintentional; (ii)
Subscriber’s breach of its Subscriber Agreement, this CPS, or applicable law; (iii) the compromise or
unauthorized use of a certificate or Private Key caused by the Subscriber’s negligence or intentional acts; or(iv) Subscriber’s misuse of a certificate or Private Key.

Indemnification by Relying Parties
To the extent permitted by law, each Relying Party shall indemnify Amazon, its partners, and any cross-signed
entities, and their respective directors, officers, employees, agents, and contractors against any loss, damage,or expense, including reasonable attorney’s fees, related to the Relying Party’s (i) breach of any service terms

43

applicable to the services provided by Amazon or its affiliates and used by the Relying Party, this CPS, or
applicable law; (ii) unreasonable reliance on a certificate; or (iii) failure to check the certificate’s status prior touse.

9.10 Term and termination
9.10.1 Term
This CPS and any amendments to the CPS are effective when published to Amazon online repository andremain in effect until replaced with a newer version.

9.10.2 Termination
This CPS and any amendments remain in effect until replaced by a newer version.

9.10.3 Effect of termination and survival
Amazon will communicate the conditions and effect of this CPS’s termination via the Amazon Repository.
The communication will specify which provisions survive termination. At a minimum, all responsibilities
related to protecting confidential information will survive termination. All Subscriber Agreements remain
effective until the certificate is revoked or expired, even if this CPS terminates.

9.11 Individual notices and communications with participantsAmazon accepts notices related to this CPS at the locations specified in §2.2. Notices are deemed effective
after the sender receives a valid and digitally signed acknowledgment of receipt from Amazon. If an
acknowledgement of receipt is not received within five days, the sender must resend the notice in paper form
to the street address specified in §2.2 using either a courier service that confirms delivery or via certified orregistered mail with postage prepaid and return receipt requested. Amazon may allow other forms of noticein its Subscriber Agreements.

9.12 Amendments
9.12.1 Procedure for amendment
This CPS is reviewed at least annually and may be reviewed more frequently. Amendments are made byposting an updated version of the CPS to the online repository. Controls are in place that are designed toreasonably ensure that this CPS is not amended and published without the prior authorization of the APPMA.

9.12.2 Notification mechanism and period
Amazon posts CPS revisions to its Repository. Amazon does not guarantee or set a notice-and-comment
period and may make changes to this CPS without notice and without changing the version number. Majorchanges affecting accredited certificates are announced and approved by the accrediting agency prior to
becoming effective. The APPMA is responsible for determining what constitutes a material change of the CPS.

449.12.3 Circumstances under which OID must be changed
The APPMA is solely responsible for determining whether an amendment to the CPS requires an OID
change.

9.13 Dispute resolution provisions
Parties are required to notify Amazon and attempt to resolve disputes directly with Amazon before resortingto any dispute resolution mechanism.

9.14 Governing law
The laws of the state of Washington State govern the interpretation, construction, and enforcement of thisCPS and all proceedings related to Amazon products and services, including tort claims, without regard to
any conflicts of law principles. The state or federal courts located in King County, Washington have nonexclusive venue and jurisdiction over any proceedings related to the CPS or any Amazon product or service.
Amazon may seek injunctive or other relief in any state, federal, or national court of competent jurisdiction
for any actual or alleged infringement of our, our affiliates, or any third party’s intellectual property or otherproprietary rights. The United Nations Convention for the International Sale of Goods does not apply to thisCPS.

9.15 Compliance with applicable law
This CPS is subject to all applicable laws and regulations, including United States restrictions on the export ofsoftware and cryptography products.

9.16 Miscellaneous provisions
9.16.1 Entire agreement
Amazon contractually obligates each RA to comply with this CPS and applicable industry guidelines. Amazon
also requires each party using its products and services to enter into an agreement that delineates the terms
associated with the product or service. If an agreement has provisions that differ from this CPS, then theagreement with that party controls, but solely with respect to that party. Third parties may not rely on orbring action to enforce such agreement.

9.16.2 Assignment
Any entities operating under this CPS may not assign their rights or obligations without the prior writtenconsent of Amazon. Unless specified otherwise in a contract with a party, Amazon does not provide notice ofassignment.

9.16.3 Severability
If any provision of this CPS is held invalid or unenforceable by a competent court or tribunal, the remainderof the CPS will remain valid and enforceable. Each provision of this CPS that provides for a limitation of
liability, disclaimer of a warranty, or an exclusion of damages is severable and independent of any otherprovision.

45

9.16.4 Enforcement (attorneys’ fees and waiver of rights)
Amazon may seek indemnification and attorneys’ fees from a party for damages, losses, and expenses related
to that party’s conduct. Amazon failure to enforce a provision of this CPS does not waive Amazon right toenforce the same provision later or right to enforce any other provision of this CPS. To be effective, waivers
must be in writing and signed by Amazon.

9.16.5 Force Majeure
Amazon is not liable for any delay or failure to perform an obligation under this CPS to the extent that thedelay or failure is caused by an occurrence beyond Amazon reasonable control. The operation of the Internet
is beyond Amazon’s reasonable control.

9.17 Other provisions
No stipulation.

Appendix A: Object Identifiers
Table 1: Signature Algorithms
Name

Object Identifier

Comments

md2WithRSAEncryption

1.2.840.113549.1.1.2

No certificates will be issued with this signaturealgorithm

md4WithRSAEncryption

1.2.840.113549.1.1.3

No certificates will be issued with this signaturealgorithm

md5WithRSAEncryption

1.2.840.113549.1.1.4

No certificates will be issued with this signaturealgorithm

sha1WithRSAEncryption

1.2.840.113549.1.1.5

No certificates will be issued with this signaturealgorithm

sha256WithRSAEncryption 1.2.840.113549.1.1.11
sha384WithRSAEncryption 1.2.840.113549.1.1.12
sha512WithRSAEncryption 1.2.840.113549.1.1.13
rsassaPss

1.2.840.113549.1.1.10

The hash algorithm is specified in the parameters data
structure

dsaWithSHA1

1.2.840.10040.4.3

No certificates will be issued with this signaturealgorithm

dsa_with_SHA256

2.16.840.1.101.3.4.3.2

ecdsa-with-SHA1

1.2.840.10045.4.1

ecdsa-with-SHA256

1.2.840.10045.4.3.2

46

No certificates will be issued with this signaturealgorithm

Name

Object Identifier

ecdsa-with-SHA384

1.2.840.10045.4.3.3

ecdsa-with-SHA512

1.2.840.10045.4.3.4

Comments

Table 2: Selected Name Attribute Types
Name

Object IdentifierComments

organizationName

2.5.4.10

Short name: O

countryName

2.5.4.6

Short name: CorganizationalUnitName 2.5.4.11

Short name: OU

commonName

2.5.4.3

Short name: CNsurname2.5.4.4

Short name: SN

givenName

2.5.4.42

Short name: GN

Appendix B: Certificate Profiles
All certificates from the Amazon PKI must meet the following requirements:• The Certificate must be a X.509 certificate.
• The version must be v3(2).
• The serial number must be a positive integer• The validity:notBefore date must be present• the IssuerUniqueId and subjectUniqueId must not be present• the signature must be a value from Table 1• the subjectPublicKeyInfo must be present• the order of extensions in the certificate may vary
• Names may only have one Attribute per RelativeDistinguishedName• the Certificate must match one of the below profiles
As described in the Amazon CP, each certificate is categorized as either a CA Certificate or a Subscriber
Certificate. Amazon does not issue Subscriber Certificates that simultaneously meet the criteria of multiple ofthe categories of Subscriber Certificates defined in the CP.

Root CA Certificates
Field

Content

issuerMust match subject

validity:notAfter

Not more than 25 years after the later of validity:notBefore or the date thecertificate was issued

subject

Must contain countryName, organizationName, and commmonName
attributes

extension:subjectKeyIdentifier

160-bit SHA-1 hash of subjectPublicKey as described in section 4.2.1.2 of
RFC528047

FieldContent

extension:basicConstraints

cA is TRUE, pathLenConstraint is not present

extension:keyUsage

digitalSignature, keyCertsign, and cRLSign bits are set, all other bits are notset

The subject Name may have additional attributes such as organizationalUnitName. The subject contents must
be validated according to the standard validation rules in section 3.2 of the Certificate Policy. The
commonName attribute must contain at least character that a letter, number, “:”, “-“, “.”, or “_” to ensure it is
not misinterpreted as a domain name or IP address. For example, the commonName may include a spacecharacter to meet this requirement.

Subordinate CA Certificates
Field

Content

validity:notAfter

Not later than the notAfter date of the signing certificate

subject

Must contain countryName, organizationName, and commonName
attributes

extension:subjectKeyIdentifier

160-bit SHA-1 hash of subjectPublicKey as described in section 4.2.1.2 of
RFC5280extension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present

extension:certificatePolicies

must contain at least one set of policyInformation containing at least a
policyIdentifer

extension:basicConstraints

cA is TRUE

extension:keyUsage

digitalSignature, keyCertsign, and cRLSign bits are set, all other bits are
not setextension:authorityInfoAccessmust contain one AccessDescription with an accessMethod of caIssuers
and a Location of type uniformResourceIdentifier and one
AccessDescription with an accessMethod of ocsp and a Location of type
uniformResourceIdentifierextension:cRLDistributionPoints

must have at least one DistributionPoint containing a fullName of type
uniformResourceIdentifier

The subject Name may have additional attributes such as organizationalUnitName. The subject contents must
be validated according to the standard validation rules in section 3.2 of the Certificate Policy. The
commonName attribute must contain at least character that a letter, number, “:”, “-“, “.”, or “_” to ensure it is
not misinterpreted as a domain name or IP address. For example, the commonName may include a spacecharacter to meet this requirement.
For subordinate CA certificates issued to organizations other than Amazon, the path length constraint in thebasicConstraints extensions is set to 0 (zero).

48

Standard Validation TLS Server Authentication Certificates
Field

Content

serialNumber

If the signatureAlgorithm uses SHA-1, the serial number must contain atleast 64 bits of randomly generated entropy

validity:notAfter

Not more than 39 months after the later of validity:notBefore or the datethe certificate was issued

subject

If the subject contains a commonName attribute, the value must be oneof the values in the subjectAlternativeName extension

extension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 2.23.140.1.2.1

extension:basicConstraints

is either absent or is empty

extension:subjectAltName

must contain at least one name and all names must either be of typedNSName or iPAddress

extension:keyUsage

digitalSignature bit must be set, keyExchange may be set, other bits
should not be set

extension:extKeyUsage

must include serverAuth, may include clientAuth

extension:authorityInfoAccessmust contain one AccessDescription with an accessMethod of caIssuers
and a Location of type uniformResourceIdentifier and one
AccessDescription with an accessMethod of ocsp and a Location of type
uniformResourceIdentifierextension:cRLDistributionPoints

must have at least one DistributionPoint containing a fullName of type
uniformResourceIdentifier

The subject and subjectAlternativeName contents must be validated according to the standard validation
rules in section 3.2 of the Certificate Policy and comply with CP sections 7.1.4.2 and 7.1.4.3

Extended Validation TLS Server Authentication Certificates
Extended Validation TLS Server Authentication Certificates follow the same profile as Standard Validation
TLS Server Authentication Certificates with the following modifications.
Field

Content

validity:notAfter

Not more than 27 months after the later of validity:notBefore or the date thecertificate was issued

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 2.23.140.1.1

49

The subject and subjectAltName contents must be validated according to the extended validation rules ofsection 3.2 of the Certificate Policy and must comply with CP sections 7.1.4.4 and 7.1.4.5. dNSNames in thesubjectAltName may not contain the ‘*’ character.

Standard Validation Code Signing Certificates
Field

Content

serialNumber

If the signatureAlgorithm uses SHA-1, the serial number must contain atleast 64 bits of randomly generated entropy

validity:notAfter

Not more than 39 months after the later of validity:notBefore or the datethe certificate was issued

subject

Must not be empty

extension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 1.3.187.1

extension:basicConstraints

is either absent or is empty

extension:subjectAltName

a General Name of type permanentIdentifier with an identifierValue
present and no assigner value present

extension:keyUsage

digitalSignature bit must be set, other bits should not be set

extension:extKeyUsage

must include codeSigning

extension:authorityInfoAccessmust contain one AccessDescription with an accessMethod of caIssuers
and a Location of type uniformResourceIdentifier and one
AccessDescription with an accessMethod of ocsp and a Location of type
uniformResourceIdentifierextension:cRLDistributionPoints

must have at least one DistributionPoint containing a fullName of type
uniformResourceIdentifier

The subject and subjectAlternativeName contents must be validated according to the standard validation
rules in section 3.2 of the Certificate Policy.

Extended Validation Code Signing Certificates
Extended Validation Code Signing Certificates follow the same profile as Standard Validation Code Signing
Certificates with the following modifications.
Field

Content

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 1.3.187.1.1

The subject and subjectAltName contents must be validated according to the extended validation rules ofsection 3.2 of the Certificate Policy and must comply with CP section 7.1.4.6.

50

Client Certificates
Field

Content

serialNumber

If the signatureAlgorithm uses SHA-1, the serial number must contain atleast 64 bits of randomly generated entropy

validity:notAfter

Not more than 39 months after the later of validity:notBefore or the datethe certificate was issued

subject

Must not be empty if the subjectAltName is empty

extension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 1.3.187.1

extension:basicConstraints

is either absent or is empty

extension:subjectAltName

may be present

extension:keyUsage

digitalSignature bit must be set, keyExchange may be set, other bits
should not be set

extension:extKeyUsage

must include at least one of clientAuth, emailProtection, Document
Signing, or Encrypting Filesystem

extension:authorityInfoAccessmust contain one AccessDescription with an accessMethod of caIssuers
and a Location of type uniformResourceIdentifier and one
AccessDescription with an accessMethod of ocsp and a Location of type
uniformResourceIdentifierextension:cRLDistributionPoints

must have at least one DistributionPoint containing a fullName of type
uniformResourceIdentifier

For each rfc822Name included in the subjectAltName, the CA ensures that Applicant either has the right touse or controls the email account.

Augmented Client Certificates
Augmented Client Certificates follow the same profile as Client Certificates.
Before issuing an Augmented Client Certificate, the CA confirms that the private key is stored on a device
that meets at least one of the following:• Certified to FIPS 140-1 or 140-2, Level 3 (or higher)• Certified to ISO/IEC 19790, Level 3 (or higher)• Certified to EAL4 (or higher) of the CWA 14169 or EN 14169 Protection Profile under the Common
Criteria (ISO/IEC 15408) framework51

• Certified as a Secure Signature Creation Device (SSCD) by an EU government entity

OCSP Signing Certificates
Field

Content

serialNumber

If the signatureAlgorithm uses SHA-1, the serial number must contain atleast 64 bits of randomly generated entropy

validity:notAfter

Not more than 39 months after the later of validity:notBefore or the datethe certificate was issued

subject

Must not be empty

extension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present

extension:certificatePolicies

must contain at least one set of policyInformation containing thepolicyIdentifier 1.3.187.1

extension:basicConstraints

is either absent or is empty

extension:keyUsage

digitalSignature bit must be set, other bits should not be set

extension:extKeyUsage

must include OCSPSigning

extension:ocsp-nocheckmust be present

Time Stamp Authority Certificates
Field

Content

serialNumber

If the signatureAlgorithm uses SHA-1, the serial number must contain atleast 64 bits of randomly generated entropy

validity:notAfter

Not more than 120 months after the later of validity:notBefore or thedate the certificate was issued

subject

Must not be empty

extension:basicConstraints

is either absent or is empty

extension:keyUsage

digitalSignature bit must be set, other bits should not be set

extension:extKeyUsage

must include timeStamping

extension:authorityInfoAccessmust contain one AccessDescription with an accessMethod of caIssuers
and a Location of type uniformResourceIdentifier and one
AccessDescription with an accessMethod of ocsp and a Location of type
uniformResourceIdentifierextension:cRLDistributionPoints

must have at least one DistributionPoint containing a fullName of type
uniformResourceIdentifierextension:authorityKeyIdentifier

keyIdentifier matches subjectKeyIdentifier of signing certificate;authorityCertIssuer and authorityCertSerialNumber are not present52