I echo Doug's concerns.  I can see this process as being useful/helpful
where the private key is off-premises, but for vanity CAs where the operator
of the root CA maintains control of the private key the same as it does for
all other issuing CAs, I think this would introduce unnecessary additional
steps.

-----Original Message-----
From: dev-security-policy
[mailto:dev-security-policy-bounces+ben=digicert....@lists.mozilla.org] On
Behalf Of Doug Beattie via dev-security-policy
Sent: Tuesday, October 24, 2017 9:44 AM
To: Gervase Markham <g...@mozilla.org>;
mozilla-dev-security-pol...@lists.mozilla.org
Subject: RE: Proposed policy change: require private pre-notification of 3rd
party subCAs

Gerv,

I assume this applies equally to cross signing, but not to "Vanity" CAs that
are set up and run by the CA on behalf of a customer.  Is that accurate?

Doug

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+doug.beattie=globalsign....@lists.mozilla.org] On Behalf Of
> Gervase Markham via dev-security-policy
> Sent: Tuesday, October 24, 2017 11:28 AM
> To: mozilla-dev-security-pol...@lists.mozilla.org
> Subject: Proposed policy change: require private pre-notification of 
> 3rd party subCAs
> 
> 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
> _______________________________________________
> dev-security-policy mailing list
> dev-security-policy@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
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