On 18/4/2024 7:58 μ.μ., Aaron Gable via Servercert-wg wrote:


    1. Section 9.6.1 adds language that imposes or makes the following
    requirements explicit:

        i. the Subscriber has been provided with the most current
        version of the Subscriber Agreement;
        ii. the applicable Subscriber Agreement is the Subscriber
        Agreement that was accepted when the Certificate was issued; and


    I am aware that ACME RFC 8555 section 7.3.3 provides a mechanism
    for updating the Subscriber Agreement ("Terms of Service" in the
    RFC). The language above seems to imply that this mechanism must
    be used whenever a CA changes their Subscriber Agreement. Has this
    mechanism been deployed and used at scale?


I concur that this appears to be a new requirement, not simply a unification of the current SA and ToS language. That's surprising, given the ballot description and purpose.

The mechanism described in RFC 8555 Section 7.3.3 for ACME servers to update the Subscriber Agreement is poorly designed, impractical, and is not fully implemented by any ACME CA that I am aware of. Specifically, the whole point of ACME is that it is automated -- operators should not need to intervene except when they make changes to their own systems. In fact, many ACME clients have no direct way to reach their operators (i.e. no email or other notification facilities), they just log to a file which the operator theoretically reads but in practice wholly ignores. So an ACME CA breaking every single ACME client until that client's operator takes manual action is a non-starter.

I'm not sure I understand this concern. ACME clients provide a mechanism for the Applicant to "accept" the Terms of Service or Subscriber Agreement and signal that action to the CA. The ballot merely says that the CA must provide their latest ToU/SA to the Applicants (this can be done via a URL presented to the Applicant), and the Applicants must signal their acceptance before proceeding.

What happens if the SA/ToS document changes? I had the impression that the ACME client would be able to see the new version and ask that the updated version is accepted. How does this process work in practice?


Thanks,
Dimitris.
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