All,
Here is the currently proposed language for the first paragraph of MRSP
section 5.3.2:

The operator of a CA certificate included in Mozilla’s root store MUST
publicly disclose in the CCADB all CA certificates it issues that chain up
to that CA certificate trusted in Mozilla’s root store that are technically
capable of issuing working server or email certificates, including such CA
certificates that are revoked but not yet expired and those CA certificates
that share the same key pair whether they are self-signed, doppelgänger,
reissued, cross-signed, or other roots. The CA operator with a certificate
included in Mozilla’s root store MUST disclose such CA certificate in the
CCADB within one week of certificate creation, and before any such CA is
allowed to issue certificates. Name-constrained CA certificates that are
technically capable of issuing working server or email certificates that
were exempt from disclosure in previous versions of this policy MUST also
be disclosed in the CCADB, but the submission of an audit report under
section 3.1 of this policy is not required.

The most recent changes made to this section 5.3.2 may be reviewed here:
https://github.com/BenWilson-Mozilla/pkipolicy/commit/b8f6e16aaf16324bcdca7653e6b8e3f2d25070c7
.

Unless there are additional comments, I am assuming that discussion on this
topic is now closed.

Thanks,

Ben

On Wed, Jul 5, 2023 at 1:28 PM Ben Wilson <bwil...@mozilla.com> wrote:

> All,
>
> This email opens up discussion of our proposed resolution of GitHub Issue
> #250 <https://github.com/mozilla/pkipolicy/issues/250>.
>
> Currently, MRSP section 5.3.2 (Intermediate CA Certificates must be
> publicly disclosed and audited) requires that all types of intermediate CAs
> capable of issuing server certificates and email certificates be disclosed
> in the CCADB. (Other root stores may have their own requirements about
> reporting other types of CAs – e.g. document-signing, code-signing, etc.,
> so this discussion is not about CCADB disclosure for those types of CAs.)
>
> Last year, we added language that required CCADB reporting of
> name-constrained CAs with the following language, “Name-constrained CA
> certificates that are technically capable of issuing working server or
> email certificates that were exempt from disclosure in previous versions of
> this policy MUST be disclosed in the CCADB prior to July 1, 2022.”  Our
> intent at that time was that it also included CA certificates that have
> been revoked but not yet expired. (One of several reasons for requiring
> disclosure of revoked CAs is that we use this information for OneCRL.)  
> However,
> there was some confusion last year about this intention because a revoked
> CA is not “technically capable of issuing working server or email
> certificates.”  See discussion -
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/XM7hWqmqmPw/m/MEVlq7REAAAJ
> The purpose of the proposal below is to clarify that revoked intermediate
> CAs must be disclosed in the CCADB. Thus, “including such CA certificates
> that are revoked but not yet expired” would be added to the first
> sentence of MRSP section 5.3.2.  It is also proposed that we remove “prior
> to July 1, 2022” because that date has passed.
>
> -----MRSP Proposal Begin-----
>
> The operator of a CA certificate included in Mozilla’s root store MUST
> publicly disclose in the CCADB all CA certificates they issue that chain up
> to that CA certificate trusted in Mozilla’s root store that are technically
> capable of issuing working server or email certificates, including such CA
> certificates that are revoked but not yet expired and those CA certificates
> that share the same key pair whether they are self-signed, doppelgänger,
> reissued, cross-signed, or other roots. The CA operator with a certificate
> included in Mozilla’s root store MUST disclose such CA certificate within
> one week of certificate creation, and before any such CA is allowed to
> issue certificates. Name-constrained CA certificates that are technically
> capable of issuing working server or email certificates that were exempt
> from disclosure in previous versions of this policy MUST also be disclosed
> in the CCADB.
>
> -----MRSP Proposal End-----
>
> Please review this proposal and provide questions or comments here in this
> thread.
>
> Thanks,
>
> Ben and Kathleen
>

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