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been revoked but not yet expired.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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