On Tue, April 7, 2015 5:31 pm, Richard Barnes wrote:
>  E. Require a certain amount of time to pass before CNNIC's re-inclusion
>  request will be considered.

I think this remains to be determined in relation to how Mozilla
implements their stated policy of a date-based check - e.g. whether this
is implemented in Firefox or NSS.

Right now, every CA that wishes to apply for inclusion goes in a queue,
and there are separate queues for new CAs versus Already included CAs (see
https://wiki.mozilla.org/CA:Schedule ). Would CNNIC's presence in the NSS
root store give it an advantage over other CAs applying either for
inclusion or an updated status?

Further, even after CAs are approved for inclusion, they're not directly
included in to a Mozilla product until one of the quarterly updates / when
there is a sufficient number of new roots. However, if implementing
restrictions are done within Firefox, it might give CNNIC an advantage
over other participants, in that CNNIC's restrictions can be lifted before
other CAs (that were ahead in the queue and approval) are included.

Another aspect to consider is Mozilla's inclusion policy with respect to
BR audits. That is,
https://wiki.mozilla.org/CA:BaselineRequirements#A_CA.27s_First_BR_Audit

It would seem like scenario 4 applies

""4. Any CA who has received a qualified BR audit opinion (i.e. failing
criteria) for its regular period of time audit and then conducts
remediation may want a point in time audit to demonstrate their
remediation efforts""

However, given the surrounding context, it would seem that, at the least,
a full performance audit showing BR compliance over at least 60 days
applies. This means CNNIC will produce new certificates, but they will not
be trusted in clients.

Alternatively, if CNNIC's disclosure of certificates reveals more BR
violations, it might be argued that an untold number of the previously
issued certificates may not conform to the BRs, which may require that the
CA create a new root, per that same section.

It would seem though that there is at least a lower bound of 60 days
before the audit begins (for a period of time audit) before CNNIC can be
considered for inclusion. If Mozilla opts not to set a minimum time, would
it incentivize a "quick" audit that doesn't address the underlying issues
noted by Mozilla? Would Mozilla accept a Point in Time Readiness
Assessment for remediation of the issues? Would CNNIC be required, the
same as other CAs doign PITRAs, to also perform a PoT assessment within 90
days of inclusion covering at least 60 days of issuance?

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