I am surprised you decided to fork the thread from here 
https://groups.google.com/forum/#!topic/mozilla.dev.security.policy/sNDN6q26_uM 
where this was already being discussed. Seems unnecessary. 

I don't agree this is a policy violation, and I doubt any CA not involved in 
the previously mentioned thread would even register that Mozilla may be 
requiring disclosure of self-signed CAs.  The only disclosure requirement this 
root may fall under is the weird "transitive" trust phrase in the policy. Note, 
this phrase is not defined in 5280 or the Mozilla policy. Can you please link 
me to the definition in an RFC? If there isn't one, until Mozilla clarifies 
what this means, the definition of transitive trust is vague, meaning any third 
interpretation is as good as the one you propose.  

Regardless, we will log the cert in the database pending resolution of the 
dispute on what this means in the Mozilla policy to avoid the debate over this 
particular root. 

Jeremy

-----Original Message-----
From: dev-security-policy 
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert....@lists.mozilla.org]
 On Behalf Of Rob Stradling via dev-security-policy
Sent: Monday, July 3, 2017 5:32 AM
To: mozilla-dev-security-pol...@lists.mozilla.org 
<dev-security-policy@lists.mozilla.org>
Subject: DigiCert policy violation - non-disclosure of 
https://crt.sh/?id=160110886

https://crt.sh/mozilla-disclosures#undisclosed has listed
https://crt.sh/?id=160110886 for over 1 week.

This is a violation of section 5.3.2 of the Mozilla Root Store Policy
v2.5 [1], which says (emphasis mine):
"All certificates that are capable of being used to issue new certificates, 
that are not technically constrained, and that directly or transitively chain 
to a certificate included in Mozilla’s root program MUST be audited in 
accordance with Mozilla’s Root Store Policy and MUST be publicly disclosed in 
the CCADB by the CA that has their certificate included in Mozilla’s root 
program. The CA with a certificate included in Mozilla’s root program MUST 
disclose this information *within a week* of certificate creation, and before 
any such subordinate CA is allowed to issue certificates."

It's a self-signed root certificate, but nonetheless there exists a signature 
chain up to an included root and so disclosure is required.


[1] 
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/

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