[Kathleen, Gerv, Wayne: Please correct me if this post misrepresents Mozilla's policy and/or current expectations. Thanks!]

Mozilla Root Store Policy v2.5 section 5.3.1 [1] permitted the non-disclosure (and, IINM, non-audit) of certain non-technically-constrained id-kp-emailProtection intermediate certificates...until yesterday: "Instead of complying with the above paragraph, intermediate certificates issued before 22nd June 2017 may, until 15th January 2018..."

According to [2], there are currently 223 non-technically-constrained intermediate certificates known to crt.sh that chain to an NSS built-in root (that has the Email trust bit set) and are capable of issuing id-kp-emailProtection certificates but not id-kp-serverAuthentication certificates.

IIUC, the Mozilla policy now requires these intermediate certificates to have already been disclosed to the CCADB and to be audited.


[1] https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#technically-constrained

[2] https://crt.sh/mozilla-disclosures#undisclosed

[3] https://crt.sh/mozilla-disclosures#undisclosedsummary

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online
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