What about subordinate CAs created after the audit letter is published?  If
both WebTrust and ETSI audit schemes assume ongoing audit reporting
responsibilities, I'd assume that  you  wouldn't need a new audit letter
every time you create a subordinate CA, which might be weekly.  The list of
subordinate CAs could be updated annually, I'd think.

-----Original Message-----
From: dev-security-policy
[mailto:dev-security-policy-bounces+ben=digicert....@lists.mozilla.org] On
Behalf Of Peter Bowen
Sent: Friday, September 23, 2016 9:18 AM
To: Kurt Roeckx <k...@roeckx.be>
Cc: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Audit requirements

On Fri, Sep 23, 2016 at 5:29 AM, Kurt Roeckx <k...@roeckx.be> wrote:
> On 2016-09-23 00:57, Peter Bowen wrote:
>>
>> Kathleen, Gerv, Richard and m.d.s.p,
>>
>> In reviewing the WebTrust audit documentation submitted by various CA 
>> program members and organizations wishing to be members, it seems 
>> there is possibly some confusion on what is required by Mozilla.  I 
>> suspect this might also span to ETSI audit documentation, but I don't 
>> know the ETSI process as well, so will leave it to some else to 
>> determine if there is confusion there.
>
>
> So at least 1 thing I miss in those audit reports is which CAs are
covered.
> If you look at the CAs they disclosed, how can we be sure that the 
> audit actually covers that CA? I think the report should cover at 
> least all root and intermediate CAs that are required to be disclosed by
Mozilla.

And many audit reports specify this.  See the following examples from the
Mozilla included CAs report.  I didn't check all -- I'm sure many more have
lists of in scope CAs.

https://cert.webtrust.org/SealFile?seal=2032&file=pdf (in the first
paragraph lists the CAs)
https://cert.webtrust.org/SealFile?seal=1998&file=pdf (first paragraph lists
the CA, appendix listing the CA details)
https://www.certsign.ro/certsign_en/files/certSIGN_Webtrust_CA.pdf
(bulleted list of CAs)
https://cert.webtrust.org/SealFile?seal=2092&file=pdf (first paragraph)
https://cert.webtrust.org/SealFile?seal=1944&file=pdf (Appendix listing CA
details) https://cert.webtrust.org/SealFile?seal=1568&file=pdf (Appendix
listing CAs)

So for many reports you don't have to guess which are covered.

Thanks,
Peter
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