As Kathleen explained, KISA does not issue any end-entity certificate (no SSL 
cert, no client cert issued by KISA). KISA issues only 5 CA certificates and no 
more.

Perhaps WebTrust criteria have not envisaged this kind of 'Super CA', whose 
role is merely administrative and somewhat 'abstract'. It is true that KISA was 
audited regarding certificate issuance, renewal, revocation, distribution, etc. 
But it was with regard to "only 5 certificates" issued and maintained by KISA.

KISA is not a CA in the usual sense.

A sensible approach would be that each LCA (who is a real CA issuing end entity 
certificates) should be audited according to the standard satisfactory to 
Mozilla before it is trusted by Mozilla.
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