Currently in the Trust Store and Trust Policy Specification in the Trusted Identities Constraints section there is a minimum field requirement on x.509 cert subject DN values stated as:
"Each identity in identities list MUST contain country (C), state or province (ST), and organization (O) RDNs. All other RDNs are optional. The minimal possible value is x509.subject: C=${country}, ST=${state}, O={organization},"
Not all identities will have a state/province value unless the identity is in the US or Canada, so the ST or S value need to NOT be required. The minimum subject DN fields should be CN=, O=, L=, C=. Signing certs commonly use these values as the minimum for subject DN.