On Mon, Dec 14, 2015 at 5:39 PM, Kathleen Wilson <kwil...@mozilla.com> wrote:
>
> Another thing to consider in updating the policy is in regards to test
> certificates versus certificates issued to customers.
> e.g. Does the disclosure need to happen before test certificates are issued?
> Or does the disclosure just need to happen before non-test certificates are
> issued? (or certificates are issued to customers, or such)

Kathleen,

There is no definition of "test certificate" so carving out a specific
exception for test certificates seems unworkable.  That being said, it
would seem reasonable that one should be able to generate a keypair
for a new CA, cut a cross-certificate from an existing CA, and issue
the first certificate(s) in one ceremony.  I don't think it is
reasonable to require a waiting period between key generation and
certificate issuance.

Therefore, I would revise my earlier recommendation, and suggest
placing a timeliness requirement on disclosure -- publicly disclose
within X days of first issuance.  If there is a strong interest in
pre-disclosure, then maybe allowing disclosure of the planned
Distinguished Name of the CA and applicable documents would be
appropriate with a supplementary disclosure of the public key after
generation.

Thanks,
Peter
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