The CPS must always be a superset of actual practices in a properly running CA.  We explain why this is a product of good design.

Root Causes 535: The CPS Is a Superset of Actual Practices

Digital certificate industry veterans Tim Callan and Jason Soroko explore the issues surrounding digital identity, PKI, and cryptographic connections in today's dynamic and evolving computing world. Best practices in digital certificates are continually under pressure from technology trends, new laws and regulations, cryptographic advances, and the evolution of our computing architectures to be more virtual, agile, ubiquitous, and cloud-based. Jason and Tim (and the occasional guest subject matter expert) will help you stay current on developments in this essential technology platform and to understand the whys and wherefores of popular Public Key Infrastructures.