Hi Gerv,

I wanted to get the latest Mozilla thoughts on the audit requirements for TCSCs 
based on the discussion we started last month.  I understand the BR requirement 
if the CA can issue server auth certificates, this was discussed here:
  
https://groups.google.com/forum/#!msg/mozilla.dev.security.policy/ZMUjQ6xHrDA/ySofsF_PAgAJ

For TCSCs that can issue secure email certs, what are the requirements in the 
new policy, 2.4?  I think they were excluded from audit requirement before, but 
in the latest Mozilla policy these CAs need to have a WT for CA audit even if 
they are Name Constrained.  

So here my questions:

Was this an intentional change?  

Is the same true for TCSCs that can issue server auth certificates (even NC CAs 
need a webtrust for CA audit)?

Are previously issued TCSCs exempt, if not, when would the audit period for 
them start?

Do these CAs need to be publicly disclosed?

Related tickets:
   https://github.com/mozilla/pkipolicy/issues/36

   https://github.com/mozilla/pkipolicy/issues/69









> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+doug.beattie=globalsign....@lists.mozilla.org] On Behalf Of
> douglas.beattie--- via dev-security-policy
> Sent: Thursday, April 13, 2017 12:33 PM
> To: mozilla-dev-security-pol...@lists.mozilla.org
> Subject: Re: Email sub-CAs
> 
> On Thursday, April 13, 2017 at 10:49:17 AM UTC-4, Gervase Markham wrote:
> > On 13/04/17 14:23, Doug Beattie wrote:
> > > In 3.2 the term Technically Constrained is not defined to be any
> > > different than the BRs (or perhaps even less restrictive).
> >
> > You mean 2.3, right?
> 
> Yes, 2.3.
> 
> > I would say Inclusion section, bullet 9 gives the definition of
> > technically constrained. For email certs, because of the bug described
> > in issue #69, it basically just says that it has to have the
> > id-kp-emailProtection EKU. It should say more, but it doesn't. That's
> > problematic, because just having an EKU isn't really a technical
> > constraint in the "TCSC" sense.
> >
> > > In 3.2
> > > this is all I can find regarding CAs that are capable of signing
> > > secure email certificates, section 9: "If the certificate includes
> > > the id-kp-emailProtection extended key usage, then all end-entity
> > > certificates MUST only include e-mail addresses or mailboxes that
> > > the issuing CA has confirmed (via technical and/or business
> > > controls) that the subordinate CA is authorized to use."
> > >
> > > There is no statement back to scope or corresponding audits.  Were
> > > secure email capable CAs supposed to be disclosed and audited to
> > > Mozilla under 2.3?
> >
> > If they did not include id-kp-serverAuth, I would not have faulted a
> > CA for not disclosing them if they met the exclusion criteria for
> > email certs as written.
> 
> OK.
> 
> > > and how it applies to Secure email, I don't see how TCSCs with
> > > secure email EKU fall within the scope of the Mozilla Policy 2.3.
> > > Can you help clarify?
> >
> > I think this is basically issue #69.
> > https://github.com/mozilla/pkipolicy/issues/69
> 
> OK, I look forward to a conclusion on that.  I hope that name constraining a
> secure email CA (either technically in the CA certificate or via business
> controls) is sufficient to avoid WebTrust Audits.  If Public disclosure helps 
> get
> us there then that would be acceptable.
> 
> > I don't think it was supposed to be the case that intermediates with
> > id-kp-emailProtection alone were supposed to be considered TCSCs.
> > After all, certs with id-kp-serverAuth alone are not TCSCs; they need
> > to have Name Constraints as well. But you are right, that's what the policy
> says.
> >
> > > OK, you're right, the number of negatives in that section got me.
> > > So, even when EKU permits just secure email, having name constraints
> > > does not exempt a CA from the Mozilla policy.  It does for BRs since
> > > email is not within scope (and discussed on the link you included in
> > > the response).  When I saw TCSC references I personally didn't
> > > realize that this was different than the BR definition of TCSC
> > > (maybe should have called this something different).
> > >
> > > Section 3.1.2.1 specifies that any CA capable of issuing secure
> > > email certificates must have a "WebTrust for CAs" audit (or
> > > corresponding ETSI audit).  This is a huge change from 3.2 and I
> > > wonder if all CAs understand this.  Even the Blog about this version
> > > does not highlight this substantial change:
> > > https://blog.mozilla.org/security/2017/04/04/mozilla-releases-versio
> > > n-2-4-ca-certificate-policy/
> >
> > I didn't realise it _was_ a substantial change. Are you saying that
> > you used to think it was fine for email-only sub-CAs to have no audits
> > at all? Is this because you considered all such CAs to be TCSCs (by
> > the Mozilla definition)?
> 
> Yes, we've been working hard to technically constrain all CAs and especially
> those operated outside of our infrastructure.  We've been following the BR
> definition: Include EKUs in all CAs, and for those that include server auth or
> secure email, include name constraints.
> 
> > Even if we didn't require it in our policy, I'm very surprised that
> > no-one else does. Which other root store policies have requirements on
> > email-only sub-CAs?
> 
> Not that I know of.
> 
> > > Obviously there are a lot of technically constrained CAs issued to
> > > organizations to run their own CAs for issuing secure email and
> > > client auth certificates.  In order for them to continue operations
> > > they now every organization needs to be publicly reported and
> > > audited (a new requirement for 2.4.1 as far as I can tell), is that right?
> >
> > This is issue #36 :-)
> > https://github.com/mozilla/pkipolicy/issues/36
> >
> > Do the CAs you are thinking of in this category have name constraints,
> > or not (either actually in the cert, or via business controls)?
> 
> Yes - they are all either name constrained either via the certificate name
> constraints or via business controls.
> 
> > > When did (does) this take effect?   Is this for new CAs, existing or
> > > both?   When would the Audit Period for these CAs need to begin?
> > >
> > > This is a side question, but does the Mozilla policy require that
> > > these CAs meet the Network Security Requirements?
> >
> > https://github.com/mozilla/pkipolicy/issues/70 :-) Not at the moment.
> 
> OK
> 
> > > Section 5.3.2 says that all CAs of the type I'm discussing must be
> > > in the CCADB.  What's the timeline for CAs to upload them?
> >
> > Well, let's figure out what the right thing to do is first. If it
> > turns out we've created new normative requirements accidentally, the
> > first thing to do is to decide whether that's what we meant. Only then
> > will we set some sort of sane implementation timeline.
> 
> Thanks Gerv.
> 
> > Gerv
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