"ACTION 6" of Mozilla's September 2018 CA Communication [1] reminded CAs
of the Mozilla Root Store Policy requirement [2] that
non-technically-constrained intermediate CA certificates...
"MUST be publicly disclosed in the CCADB by the CA that has their
certificate included in Mozilla's root program. The CA with a
certificate included in Mozilla's root program MUST disclose this
information within a week of certificate creation, and before any
such subordinate CA is allowed to issue certificates."
In their responses to "ACTION 6" [3], most CAs indicated that...
"We are aware of the requirements for intermediate certificate
disclosure and have processes in place to ensure that these
requirements are met"
There are currently 20 undisclosed non-technically-constrained
intermediates, belonging to 6 Root Owners, on "Rob's naughty list" [4]
(snapshot at [5]). All 20 were undisclosed and listed (on [4]) on the
day the responses to [1] were due (September 30th), which means that
they have not been disclosed "within a week of certificate creation".
So, ISTM that the "processes in place to ensure that these requirements
are met" are insufficient/broken for at least the following Root Owners:
- Certicámara
- DigiCert
- DocuSign (OpenTrust/Keynectis)
- SECOM Trust Systems CO., LTD.
- SwissSign AG
- Telia Company (formerly TeliaSonera)
Wayne, Kathleen:
Given the number of times that all the CAs in Mozilla's Root Program
have been reminded about Mozilla's requirements for disclosing
intermediate certs, I wouldn't blame you if you decided to add these 20
intermediate certs [5] to OneCRL immediately!
[1]
https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J00003rMGLL
[2]
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#532-publicly-disclosed-and-audited
[3]
https://ccadb-public.secure.force.com/mozillacommunications/CACommResponsesOnlyReport?CommunicationId=a051J00003rMGLL&QuestionId=Q00078,Q00079
[4] https://crt.sh/mozilla-disclosures#undisclosed
[5] https://crt.sh/reports/20181009_MozillaDisclosures.html#undisclosed
--
Rob Stradling
Senior Research & Development Scientist
Email: r...@comodoca.com
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