Greetings again, This has been posted on our CA wiki page of transition instructions related to CA implementation of the S/MIME BRs - https://wiki.mozilla.org/CA/Transition_SMIME_BRs#Audit_Migration_Plan. Thanks, Ben
On Fri, Jun 16, 2023 at 10:36 AM Ben Wilson <bwil...@mozilla.com> wrote: > Greetings, > > Our proposal for a migration plan towards having Certification Authorities > (CAs) follow the CA/Browser Forum’s Baseline Requirements for S/MIME > Certificates (S/MIME BRs) is as follows, keeping in mind that the Effective > Date for version 1.0.0 of the S/MIME BRs is September 1, 2023, and assuming > that ETSI and WebTrust audit criteria are in place for S/MIME BR audits by > September 1, 2023. > > Any root CA certificate being considered for inclusion after September 1, > 2023, must be audited according to the S/MIME BRs if the email trust bit is > to be enabled, and the CA operator’s CP or CPS must state that they follow > the current version of the S/MIME BRs. Note that the CA operator’s first > S/MIME BR audit may be a Point-in-Time audit if the audit period will be > less than 60 days, and the audit statement may list non-compliances to be > resolved within the next annual audit period. > > CA root certificates and subordinate CA certificates that are technically > capable of issuing S/MIME certificates that chain up (either directly or > transitively) to a root certificate that has the email (S/MIME) trust bit > enabled in Mozilla's CA Certificate Program shall be audited with a > Period-of-Time audit according to the S/MIME BRs between September 1, 2023, > and August 31, 2024, and annually thereafter. For CA operators to maintain > their current annual audit cycles, the new S/MIME BR audit should be > provided along with the other audits that the CA operator provides annually. > > - > > The audit period start date for the first S/MIME BR audit will be > September 1, 2023, or earlier. > - > > At the CA operator’s option, the first S/MIME BR audit may cover > the entire audit period. > - > > The initial audit period start date for the first S/MIME BR audit > cannot be before the effective date of a CA operator’s CP or CPS that > confirms the CA operator’s compliance with the current version of the > S/MIME BRs. > - > > If the CA operator’s existing regular audit period for other audit > types ends after October 30, 2023, then we will expect to receive an S/MIME > BR audit that covers September 1, 2023, through the end of that audit > period (i.e. a Period-of-Time audit). > - > > If the CA operator’s first S/MIME BR audit period would be less > than 60 days (e.g. audit period being September 1, 2023, to October 30, > 2023), then a Point-in-Time audit may be performed. > - > > The first S/MIME BR audit for each CA root certificate and subordinate > CA certificate may include a reasonable list of non-compliances that the CA > operator (or subordinate CA operator) is not yet in compliance with. > - > > Only one Incident Bug needs to be filed containing the list of the > non-compliances in a CA operator’s first S/MIME BR audit. > - > > Submission of the second S/MIME BR audit report is expected to confirm > that the issues that were listed in the first S/MIME BR audit report have > been resolved. > > We look forward to your constructive feedback on the proposed transition > timeline. > > Regards, > > Ben and Kathleen > -- You received this message because you are subscribed to the Google Groups "dev-security-policy@mozilla.org" group. To unsubscribe from this group and stop receiving emails from it, send an email to dev-security-policy+unsubscr...@mozilla.org. To view this discussion on the web visit https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/CA%2B1gtaZn5KvaVPZ0kcAXmP5jSyoTQMi35xNBrYoXYE6%2Bb9koTg%40mail.gmail.com.
