One of the ways in which the number of organizations trusted to issue
for the WebPKI is extended is by an existing CA bestowing the power of
issuance upon a third party in the form of control of a
non-technically-constrained subCA. Examples of such are the Google and
Apple subCAs under GeoTrust, but there are others.

Adding new organizations to the list of those trusted is a big deal, and
currently Mozilla has little pre-insight into and not much control over
this process. CAs may choose to do this for whoever they like, the CA
then bears primary responsibility for managing that customer, and as
long as they are able to file clean audits, things proceed as normal.

Mozilla is considering a policy change whereby we require private
pre-notification of such delegations (or renewals of such delegations).
We would not undertake to necessarily do anything with such
notifications, but lack of action should not be considered permissive in
an estoppel sense. We would reserve the right to object either pre- or
post-issuance of the intermediate. (Once the intermediate is issued, of
course, the CA has seven days to put it in CCADB, and then the
relationship would probably become known unless the fields in the cert
were misleading.)

This may not be where we finally want to get to in terms of regulating
such delegations of trust, but it is a small step which brings a bit
more transparency while acknowledging the limited capacity of our team
for additional tasks.

Comments are welcome.

Gerv
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