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I have a DMS system(alfresco) that needs to sign approx 50.000 valid signatures a year. The signing certificate needs to be acquired from one of the affiliated sub-CA's. So according to the Adobe CDS certificate policy, are they obligating me to use a hardware HSM or usb Token? I want to use SoftHSM instead. It is free & opensource (but no hardware).

Is this possible?

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The CDS Certificate Policy (available here) specifies in section 6.1.1

Subscriber key pairs must be generated in a manner that ensures that the private key is not known by anybody other than the Subscriber or a Subscriber’s authorized representative. Subscriber key pairs must be generated in a medium that prevents exportation or duplication and that meets or exceed FIPS 140-1 Level 2 certification standards.

SoftHSM is not FIPS 140-1 Level 2 compliant. As far as I know, level 2 and upper requires a hardware cryptographic module.

Note that the AATL program (successor of CDS) has similar requirements but it provides a larger set of Certification Authority which could provide you either a physical signature certificate or a signature SaaS solution.

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