On 13/05/16 22:09, Richard Barnes wrote:
<snip>
Thanks for explaining the specifics, Rob.  To restate and check my
understanding, this is a "Y-shaped" scenario, with the following CAs (by
CN):

(1) AddTrust External CA Root (included, owned by Comodo)
(2) UTN-USERFirst-Hardware (included, owned by Comodo)
(3) Network Solutions Certificate Authority (included, owned by Web.com)
(4) Network Solutions EV Server CA

... and the following certificates (in graphviz notation):

digraph {
  1 -> 3;
  2 -> 3;
  3 -> 3;
  3 -> 4;
}

And the question is who needs to disclose the (3->4) certificate.

Yes, that's my question.

FWIW Rob has exactly specified what I, as a relying party, would want
Mozilla to do on my behalf although I would interpolate ("... and audited")
each time he mentions disclosure.


This seems like a pretty sensible policy to me.  One could consider it as
parallel to a hypothetical non-cross-signed scenario where the root relies
on the intermediate to disclose its subtree, then the root discloses the
intermediate.


I agree with him that the current policy does not clearly state this.


The current policy has the blessing / curse of using the passive voice
("...MUST either be technically constrained or be publicly disclosed and
audited."), which obscures which agent must do the disclosing.  But that
also means (ISTM) that Rob's suggested resolution is consistent with the
policy.  As long as the subordinate below the cross-signed intermediate is
disclosed, it doesn't matter who disclosed it; but if it's not, then all
the cross-signers are out of compliance.

I agree that my suggested resolution is consistent with the Mozilla CA Policy.

However, it seems to be inconsistent with what Mozilla's recent CA Communication requires CAs to do by the end of June (emphasis mine): "ACTION #2: Beginning with Version 2.1 of Mozilla's CA Certificate Policy, for any certificate which directly or transitively chains to the root certificates you currently have included in Mozilla's CA Certificate Program, which are capable of being used to issue new certificates, and which are not technically constrained as described in Section 9 of Mozilla's CA Certificate Inclusion Policy, *you are required* to provide public-facing documentation about the certificate verification requirements and annual public attestation of conformance to said requirements. *This includes certificates owned by, operated by, or issued by third parties, whether or not those issuing certificates are already part of Mozilla's CA Certificate Program, if they have been cross-signed by a certificate that directly or transitively chains to your root certificate.* To facilitate this public disclosure, Mozilla is requiring that these certificates, as well as their CP/CPS and audit statements, be entered into Mozilla's CA Community in Salesforce."

I see that Kathleen has added the following text to https://wiki.mozilla.org/CA:CertificatePolicyV2.3#Proposed_Changes_Currently_in_Discussion "Update transitive disclosure policy to reduce duplication of full CA hierarchies Update section 8 of Mozilla's CA Certificate Inclusion policy to say that transitive disclosure is not required when the subject of the CA-certificate is also the subject of a certificate included directly in the Mozilla trust store."

However, ISTM that a "proposed change currently in discussion" is less authoritative than the CA Communication (which, as I've said, seems to explicitly require multiple disclosures of the same intermediate when multiple trust paths exist).

Assuming everyone's happy with my suggested resolution, please would you update the requirements for "ACTION #2" before the end of June (the earlier the better!) so that multiple disclosures are not required?

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online
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