Jakob,

On Mon, Mar 19, 2018 at 9:48 PM, Jakob Bohm via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On 17/03/2018 01:23, Wayne Thayer wrote:
>
> Note, that if it is reasonably certain/validated that the only activity
> is maintaining CRLs/OCSP for the remaining unexpired certificates, then
> most of the updated BR requirements (such as CAA, CT and stricter
> validation methods) become noops, since no validations are being done,
> no CAA strings are accepted, no new certificates are issued etc.
>
> I agree in practice, but if a WebTrust audit were to be conducted it would
contain a number of qualifications, or as is the case here, no ETSI audit
statement would be issued.

We may thus be looking at the 12 months of an orderly shutdown of a
> CA, as per section 5.8 of the standard CPS template, and might
> reasonably consider accepting the lack of normal activity levels for
> such a situation.  The BRs and Mozilla policy seem silent on the
> subject,
>
> Are you suggesting that we delay removal of this root until all leaf
certificates expire?

Are you suggesting that the BRs be modified so a CA that has ceased
issuance can obtain a clean audit report without meeting all current BR
requirements?

The only critical thing that seems to be missing is a BR audit report to
> confirm that no issuance is taking place and the revocation management
> and CA private key protection is still being done properly.
>
> Continued audit reports are indeed critical to maintaining trust in a CA
even after it has ceased issuance.

- Wayne
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