On Thursday, August 25, 2016 at 8:07:05 PM UTC, Kathleen Wilson wrote:
> > This request by the Government of Japan, Ministry of Internal 
> > Affairs and Communications, is to include the GPKI 'ApplicationCA2 Root' 
> > certificate and enable the Websites trust bit. This new root certificate 
> > has been created in order to comply with the Baseline Requirements, and 
> > will eventually replace the 'ApplicationCA - Japanese Government' root 
> > certificate that was included via Bugzilla Bug #474706. Note that their 
> > currently-included root certificate expires in 2017, and will be removed 
> > via Bugzilla Bug #1268219.
> > 
> > The request is documented in the following bug:
> > https://bugzilla.mozilla.org/show_bug.cgi?id=870185
> 
> Thank you to those of you who reviewed and commented on this request from 
> Japan GPKI to include the GPKI 'ApplicationCA2 Root' certificate and enable 
> the Websites trust bit. 
> 
> This discussion is on hold pending completion of the following action items 
> by the CA:
> 
> 1) Update the CP/CPS documents with sufficient detail to describe the 
> policies and procedures that apply to this root cert and all certs that chain 
> to it.
> Note that I added a new section to the Recommended Practices wiki page to 
> provide pointers to previous reviews of CP/CPS documents, so CAs can see both 
> good and not-so-good examples.
> https://wiki.mozilla.org/CA:Recommended_Practices#CP.2FCPS_Documents_will_be_Reviewed.21
> 
> 2) Provide an updated BR audit statement
> 
> Thanks,
> Kathleen

GPKI recently provided an updated CPS and also has provided a BR audit 
statement. I've reviewed the information provided and have the following 
comments:

== Good ==
* GPKI is requesting a name constraint to go.jp
* Section 1 states that the BRs take precedence over the CPS
* Problem reporting information is published at 
http://www.gpki.go.jp/apca2/index.html

== Meh ==
* Full name of the BRs is cut off in section 1: “CA/Browser  Forum,  Baseline  
Requirements for the Issuance and Management of Publicly.”
* Revision history doesn’t state what was changed (Mozilla policy 3.3 requires 
a “dated changelog” but doesn’t explicitly require a description of changes to 
be included)
* Neither the CPS or the BR Self Assessment explain how GPKI identifies 
high-risk certificate requests
* There are separate CPS’s for the root and it’s subordinate CA. Some of the 
required information (CAA, domain validation methods) is only contained in the 
sub CA’s CPS.
* The CPS doesn’t contain an explicit open-source license statement as 
encouraged by Mozilla policy 3.3(3)
* A minimal description of the methods used by the CA to perform domain 
authorization was added to section 4.1.2. How is method 3.2.2.4.1 used? I don’t 
think enough information is provided to comply with Mozilla policy 2.2(3) that 
states “The CA's CP/CPS must clearly specify the procedure(s) that the CA 
employs”. However, the fact that this CA will be name constrained to go.jp 
reduces my concern over this.
* There are references to the “sterling committee” in the CPS. I believe this 
is meant to translate to “steering committee”.

== Bad ==
* CPS docs are not assigned a version number (Mozilla policy 3.3)
* I can’t find a current WebTrust for CAs audit statement - I've requested a 
translated copy in the bug. There may be confusion over the fact that two 
audits are required.
* The translated WebTrust BR audit report does not include all the information 
required by Mozilla policy 3.1.4. Based on information in the bug I believe 
this meant to be a period-of-time audit, but it looks like a point-in-time 
readiness audit.

Wayne
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