Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-28 Thread Pedro Fuentes
Hello. OK. I see your point. I was thinking on the end date of the audit report that was uploaded. Chrome's approach is to count 90 days after that, so typically we open the audit case and then, within those 90 days, we send the self-assessment. But I guess the result is the same. Txs El

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread Ben Wilson
Hi Pedro, I think that the proposed language works with the scenario you present. In other words, you have 455 days after your previous year's audit end date to submit your self assessment to the CCADB. This can be done in conjunction with submitting your audit information in the CCADB using

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread Pedro Fuentes
I got lost here "CA operators SHOULD submit the link to their self-assessment at the same time as when they update their audit records (within 455 calendar days after the CA operator's earliest appearing root record's "BR Audit Period End Date" for the preceding audit period)." Typically we'd

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread Ben Wilson
Thanks, Bruce, It would be based on the significance of revisions and compliance dates found in the Baseline Requirements and on when the template was updated and approved by the participating root stores. Ben On Thu, Jul 27, 2023 at 9:13 AM 'Bruce Morton' via dev-security-policy@mozilla.org

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread 'Bruce Morton' via dev-security-policy@mozilla.org
Looks good. There might be an issue with the version of the self-assessment template as I don't think the CAs know when it will be updated. Is there a schedule or is this random? On Thursday, July 27, 2023 at 11:01:17 AM UTC-4 Ben Wilson wrote: > Thanks again. > > How about this language? > >

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread Ben Wilson
Thanks again. How about this language? CA operators with CA certificates capable of issuing working TLS server certificates MUST submit a link to their annual [Compliance Self-Assessment](https://www.ccadb.org/cas/self-assessment) via the CCADB. The initial annual self-assessment must be

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread 'Bruce Morton' via dev-security-policy@mozilla.org
Google policy states "The initial annual self assessment must be completed and submitted to the CCADB within 90 calendar days from the CA owner's earliest appearing root record “BR Audit Period End Date” that is after December 31, 2022." You could use the same approach. Note, that for a CA to

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread Ben Wilson
Thanks, Bruce. If we took that approach, then the language in MRSP section 3.4 might read, "Effective January 1, 2024, CA operators with CA certificates capable of issuing working TLS server certificates MUST submit their [Compliance Self-Assessment](https://www.ccadb.org/cas/self-assessment) at

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-27 Thread 'Bruce Morton' via dev-security-policy@mozilla.org
Hi Ben, It would be great to get your feedback on my proposal above as I would like to put this into a human process which is kind of analog. The 365/366 proposal means we would need to do it, say every 330 days to ensure we stay compliant. This would mean the schedule would continue to move

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-26 Thread Ben Wilson
And, for section 3.3 (CPs and CPSes), I am thinking that the same change should be made from 365 to 366 days, and that item 4 would read, "all CPs, CPSes, and combined CP/CPSes MUST be reviewed and updated as necessary at least once every 366 days." Ben On Wed, Jul 26, 2023 at 3:35 PM Ben Wilson

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-07-26 Thread Ben Wilson
All, For submission of self-assessments, what do people think about "at least every 366 days" instead of the original proposal of 365 days? That gives flexibility for leap years. Ben On Thu, Jun 29, 2023 at 9:48 PM Antti Backman wrote: > I concur to Bruce's consern, > > Albeit not directly

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-06-29 Thread Antti Backman
I concur to Bruce's consern, Albeit not directly conserning this discussion, we already have this issue in our hands: https://www.chromium.org/Home/chromium-security/root-ca-policy/#6-annual-self-assessments But yes, this will be moving target, I would propose that this could be tight

Re: MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-06-29 Thread 'Bruce Morton' via dev-security-policy@mozilla.org
The issue I have with "at least every 365 days" is that I like to put something on the schedule and do it the same month every year. We do this with our annual compliance audit. If we have to provide the self-assessment at least every 365 days, then each year it will be earlier to provide some

MRSP 2.9: Issue #123: Annual Compliance Self-Assessment

2023-06-23 Thread Ben Wilson
All, Historically, Mozilla has required that CAs perform an annual Self-Assessment of their compliance with the CA/Browser Forum's TLS Baseline Requirements and Mozilla's Root Store Policy (MRSP). See https://wiki.mozilla.org/CA/Compliance_Self-Assessment. While there has not been any