On Thursday, August 3, 2017 at 9:49:41 AM UTC-7, Jonathan Rudenberg wrote:
> Even absent the BR-violating certificates and disclosure timeline, I believe 
> this cross-sign is problematic because it appears to circumvent the 
> prerequisites and process described in 
> https://bugzilla.mozilla.org/show_bug.cgi?id=1311832 for StartCom’s 
> application for re-inclusion into the Mozilla root store. It’s not clear to 
> me what the point of those requirements is if they can be avoided by 
> obtaining cross-signatures from other CAs that are currently trusted by 
> Mozilla.

It is common practice for a CA to get cross-signed by a currently-included CA, 
so their cert chain is trusted while they are going through Mozilla's long 
inclusion process. This is OK, as long as the currently-included CA ensures 
that the subCA follows Mozilla's Root Store Policy.
See section 5.3 of 
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/

I would have a problem if Certinomis cross-signed with the old StartCom roots 
for which we do not trust certs issued after October 2016. In my opinion, that 
would be grounds for removing Certinomis' roots.

However, I think it is fine for Certinomis to cross-sign with new StartCom 
subCA certs, as long as Certinomis ensures that Mozilla's Root Store Policy is 
being followed. 


> As far as the misissued certificates are concerned, here are a couple points 
> to consider:
> 
> 1) Many of the certificates are improperly validated “test” certificates, a 
> practice that is extremely problematic and indicates a lack of or 
> circumvention of technical controls.


Yes, this is problematic. But other CAs have also had this problem, and for the 
other CAs we have worked with them to ensure the practice is stopped, 
tools/process put in place to prevent it in the future, problematic certs 
revoked, etc. But this type of mis-issuance has not yet been considered grounds 
for adding the relevant intermediate cert to OneCRL.


> 2) StartCom's systems are apparently new, but they have failed to correctly 
> implement simple aspects of the certificate profile such as keyUsage bits and 
> character encodings. These issues are trivially detected by running tools 
> like certlint and should have been caught well before the system made it into 
> production.


This is the part that particularly concerns me. I would expect StartCom to be 
on their best behavior and setting up an exemplary PKI. These types of mistakes 
should not be happening. This is the main reason I am considering adding the 
two intermediate certs to OneCRL and telling the CA to start over, and make 
sure they do it right this time.

Thanks,
Kathleen
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