SECMP 0073: Alteration of SMKI Repository information and documentation

Date raised 23/04/2019 Modifications Path Path 3 – Self Governance
Current stage Not Applicable Overall status Initial Consideration
Refinement? No Urgent modification? No
Proposer name Gordon Hextall Proposer's organisation SMKI PMA


Problem Statement

The policy intent in respect of the SMKI Repository is that no information, document or other material that is placed in the SMKI Repository should be deleted, changed, altered, amended, modified or replaced in any way. This is to enable all Eligible Subscribers and Relying Parties to be reliant on the integrity of the information held in the SMKI Repository the content of which is described in SEC Section L5.1.

SEC Section L5 places obligations on the SMKI PMA to lodge, or to require the DCC to lodge, modified information or documents in the SMKI Repository. However, ambiguity within SEC Section L, due to different interpretations of Section L3.22, has lead to the DCC deleting information in SMKI Organisation and Device Certificates without SMKI PMA governance or approval. BEIS has advised that the DCC is not intended, under the SEC, to make any changes to information in the SMKI Repository and that the DCC is a ‘person’ within the meaning of SEC Section L5.5 and L5.6. The proposer wishes to remove any ambiguity from the SEC drafting and ensure there are robust governance arrangements in place.

The full Draft Proposal can be found here

Latest Progress

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Proposed implementation timetable

Draft Proposal raised: 23 April 2019

To be considered by the Change Sub-Committee: 28 May 2019

Implementation date



  • Modification Proposal Raised
  • Initial Modification Report
  • Refinement Process
  • Modification Report
  • Change Board Vote
  • Modification Decision
DP073 Draft Proposal v0.2
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