My previous message is not showing up in Google Groups, so trying again (with 
some re-phrasing)...

All,

ETSI audit statements typically do not specify the audit period start and end 
dates. And it is very difficult to determine if their audit statement is for a 
point-in-time audit versus a period-of-time audit. 

ETSI has a concept of their ETSI certification being valid for one to three 
years, and will list an expiration date for their ETSI certification that is in 
the future. Many of the CAs mistakenly enter their ETSI certification dates for 
the audit period start and end dates.

~~

Definition (From BRs):
Audit Period: In a period‐of‐time audit, the period between the first day 
(start) and the last day of operations (end) covered by the auditors in their 
engagement. (This is not the same as the period of time when the auditors are 
on‐site at the CA.)"

~~

Here is the requirement according to the Baseline Requirements:
https://cabforum.org/baseline-requirements-documents/
Section 8.1:"The period during which the CA issues Certificates SHALL be 
divided into an unbroken sequence of audit periods.
An audit period MUST NOT exceed one year in duration."

Here's the requirement according to Mozilla's Policy:
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy#audit-parameters
"Full-surveillance period-of-time audits MUST be conducted and updated audit 
information provided no less frequently than annually. Successive audits MUST 
be contiguous (no gaps)."

~~

The April 2017 CA Communication specified the content we expect to be in all 
audit statements now.
https://wiki.mozilla.org/CA/Communications#April_2017

Every CA stated that they understand the requirements, and no CA raised concern 
about audit periods.
https://ccadb-public.secure.force.com/mozillacommunications/CACommResponsesOnlyReport?CommunicationId=a05o000003WrzBC&QuestionId=Q00018,Q00032

So, why are so many ETSI audits still not meeting these requirements?

~~

Mozilla's policy lists the specific information that must be included in each 
audit statement document:
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy#public-audit-information

~~

How do we get all auditors to start meeting our audit statement requirements?

Why haven't all included CAs communicated these requirements to their auditors?

Why am I seeing so many audit statements (particularly ETSI audit statements) 
that do not meet our requirements?

I will greatly appreciate thoughtful and constructive ideas on this.

Thanks,
Kathleen

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