This issue was brought up in the thread that kicked off the 2.6 root store
policy update [1]. Mozilla policy section 5.3.2 requires CAs to disclose
new unconstrained intermediate CA certificates within one week of creation.
Section 8 covers [in my opinion] transfers of roots but not intermediates.
This leaves a loophole for a CA to create a new intermediate CA
certificate, then transfer it without notice or approval. This problem also
applies to cross-signatures from one CA to another.

I am aware of three potential solutions:

1. In section 5.3.2, require CAs to also disclose a change in the ownership
or control of an unconstrained intermediate CA certificate within one week
of the change.

2. Modify section 8 to explicitly include transfers of trust via
intermediate CA certificates and cross signatures. Under section 8.1, this
would require notice and approval:

If the receiving or acquiring company is new to the Mozilla root program,
> there MUST be a public discussion regarding their admittance to the root
> program, which Mozilla must resolve with a positive conclusion before
> issuance is permitted.
>
3. Require organizations that are receiving subordinate CA certificates to
go through the whole Mozilla inclusion process as if they were applying for
a new root.

I would appreciate everyone's input on this topic.

This is: https://github.com/mozilla/pkipolicy/issues/122

[1] https://groups.google.com/d/msg/mozilla.dev.security.policy/
xGGGaI1_uo0/POMANRWRAAAJ
-------

This is a proposed update to Mozilla's root store policy for version
2.6. Please keep discussion in this group rather than on GitHub. Silence
is consent.

Policy 2.5 (current version):
https://github.com/mozilla/pkipolicy/blob/2.5/rootstore/policy.md
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