On 2014-02-18 14:28, Ruy Ramos wrote:
The brazilian root CA for ICP-Brasil has complete accountability for the
operations of its subsidiary CAs. That is achieved by annual audit
procedures take into effect by ITI, the federal agency that plays the
role of Root CA of ICP-Brasil.

Please note that CAB baseline requirements says this:

17. Audit

Certificates that are capable of being used to issue new certificates MUST either be Technically Constrained in line with section 9.7 and audited in line with section 17.9 only, or Unconstrained and fully audited in line with all remaining requirements from section 17. A Certificate is deemed as capable of being used to issue new certificates if it contains an X.509v3 basicConstraints extension, with the cA boolean set to true and is therefore by definition a Root CA Certificate or a Subordinate CA Certificate.

And:

17.9 Regular Quality Assessment of Technically Constrained Subordinate CAs

During the period in which a Technically Constrained Subordinate CA issues Certificates, the CA which signed the Subordinate CA SHALL monitor adherence to the CA’s Certificate Policy and the Subordinate CA’s Certification Practice Statement. On at least a quarterly basis, against a randomly selected sample of the greater of one certificate or at least three percent of the Certificates issued by the Subordinate CA, during the period commencing immediately after the previous audit sample was taken, the CA shall ensure all applicable Baseline Requirements are met.


So it's either:
- They're Technically Constrained, you need to audit them every 3 months
- They're not Technically Constrained and need a audit every year, and we could include them directly as root CAs.


Kurt

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