Hi Christophe,
Thanks for pointing out this issue. I will work this into my edits on
Github so that the scope of the Mozilla Root Store Policy for S/MIME
certificates is narrowed. In other words, I'll add the language "and the
inclusion of a rfc822Name or an otherName of type id-on-SmtpUTF8Mailbox in
the subjectAltName extension" to the draft of version 2.9 that I'm working
on so that an S/MIME certificate, for purposes of the MRSP, must have not
only the emailProtection EKU, but also an RFC822 name or an otherName of
type id-on-SmtpUTF8Mailbox in the SAN.
Does that resolve your concern?
Thanks,
Ben


On Thu, Jul 6, 2023 at 9:47 AM Christophe Bonjean <
christophe.bonj...@globalsign.com> wrote:

> Hi Ben and Kathleen,
>
>
>
> “Insofar as the *S/MIME* or TLS Baseline Requirements *attempt to define
> their own scope*, the *scope of this policy (section 1.1) overrides that*.
> CA operations relating to issuance of all S/MIME or TLS server certificates
> in the scope of this policy SHALL conform to the S/MIME or TLS Baseline
> Requirements, as applicable.”
>
>
>
> Section 1.1 of the MRSP states “[…], such end entity certificates having
> either: an Extended Key Usage (EKU) extension that contains one or more of
> these KeyPurposeIds: anyExtendedKeyUsage, id-kp-serverAuth,
> *id-kp-emailProtection*; or [….]”
>
>
>
> Section 1.1 of the SBR states “An S/MIME Certificate for the purposes of
> this document can be identified by the existence of an Extended Key Usage
> (EKU) for id-kp-emailProtection (OID: 1.3.6.1.5.5.7.3.4) *and the
> inclusion of a rfc822Name or an otherName of type id-on-SmtpUTF8Mailbox in
> the subjectAltName extension*.”
>
>
>
> Is the intention of the Mozilla Root Store Policy update to apply the
> SMIME BRs to all certificates with the EKU EmailProtection, including
> certificates without an rfc822Name or an otherName, such as certificates
> for document and pdf signing purposes?
>
>
>
> I recall these use cases being discussed in the working group and
> intentionally out-scoping them from the SBRs to avoid unintended adverse
> effects, so wonder how to interpret the proposed update to the MRSP.
>
>
>
> Kind regards,
>
>
>
> Christophe
>
>
>
> *From:* dev-security-policy@mozilla.org <dev-security-policy@mozilla.org> *On
> Behalf Of *Ben Wilson
> *Sent:* Wednesday, June 14, 2023 12:54 AM
> *To:* dev-secur...@mozilla.org <dev-security-policy@mozilla.org>
> *Subject:* MRSP 2.9: S/MIME BRs and Audits
>
>
>
> All,
>
> This email opens up discussion of our proposed resolution of GitHub Issue
> #258 <https://github.com/mozilla/pkipolicy/issues/258> (SMIME Baseline
> Requirements).
>
> We plan to add requirements to version 2.9 of the Mozilla Root Store
> Policy <https://www.mozilla.org/projects/security/certs/policy/>
> regarding the CA/Browser Forum’s S/MIME Baseline Requirements.
>
> We propose to update Mozilla’s Root Store Policy to require annual S/MIME
> BR audits as follows.
>
>    - Section 2.2, second bullet point modified to directly reference that
>    email verification must be in accordance with section 3.2.2 of the S/MIME
>    BRs
>    - Section 2.3,
>
>
>    - First paragraph – add the following sentence (as a second sentence):
>
> Certificates issued on or after September 1, 2023, that are capable of
> being used to digitally sign or encrypt email messages, and CA operations
> relating to the issuance of such certificates, MUST conform to the latest
> version of the CA/Browser Forum Baseline Requirements for the Issuance and
> Management of Publicly-Trusted S/MIME Certificates.
>
> o    Change the remaining references of “Baseline Requirements” in this
> section to “S/MIME and TLS Baseline Requirements”. To indicate that the
> statements apply to both.
>
>    - Section 3.1.2
>
>
>    - Add ETSI TS 119 411-6 as audit criteria
>       - Add WebTrust for CAs - S/MIME as audit criteria
>
>
>    - Sections 3.2, 3.3, 5.2, 7.1
>
>
>    - Change “Baseline Requirements” to “S/MIME and TLS Baseline
>       Requirements”. To indicate that the statements apply to both.
>
>
>    - Section 5.1 add a statement:  “The following curves are not
>    prohibited, but are not currently supported:  P-521, Curve25519, and
>    Curve448.”
>
>
>    - And add a sentence:  “EdDSA keys MAY be included in certificates
>       that chain to a root certificate in our root program if the certificate
>       contains ‘id-kp-emailProtection` in the EKU extension. Otherwise, EdDSA
>       keys MUST NOT be included.”
>
>
>    - Section 5.3.1
>
>
>    - Move the following sentence from the end of the current second
>       paragraph up to its own stand-alone paragraph.
>
>
>    - "The conformance requirements defined in section 2.3 of this policy
>          also apply to technically constrained intermediate certificates."
>
>
>    - Revise last paragraph with proposed new text:
>
>
>    - “If the intermediate CA certificate includes the
>          id-kp-emailProtection extended key usage, then to be considered 
> technically
>          constrained, it MUST comply with section 7.1.5 of the S/MIME
>          Baseline Requirements <https://cabforum.org/smime-br/> and
>          include the Name Constraints X.509v3 extension with constraints on
>          rfc822Name, with at least one name in permittedSubtrees, each such 
> name
>          having its ownership validated according to section 3.2.2 of the 
> S/MIME
>          Baseline Requirements <https://cabforum.org/smime-br/>.”
>
>
>    - Change remaining existing occurrences of “Baseline Requirements” to
>    “TLS Baseline Requirements”.
>
> We look forward to your constructive feedback on these proposed changes to
> the MRSP.
>
>
>
> We will start a separate discussion about dates/timelines and when
> compliance audits will be due for these new requirements.
>
>
>
> Regards,
>
>
>
> Ben and Kathleen
>
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