Hi Nick,

I had been thinking that 119 403-2 was just intended as an attestation
statement template, similar to the WebTrust reporting guidance [1]. Now I
understand that it can include more substantial requirements.

This is certainly not a complete list, but specific to this discussion I
would start with the following concerns:
* Reporting on major and minor non-conformities - I have yet to ever see an
ETSI attestation listing a major non-conformity, but I have shared several
examples listing minor non-conformities with ETSI representatives. We need
standards that require consistent disclosure of all types of
non-conformities in attestation statements. Disclosure is required even if
a CA fixes a non-conformity within an acceptable time frame (based on ETSI
standards).
* Disclosure when a CA violates the BR revocation timeline requirements,
even if their actions are perfectly acceptable under ETSI standards for
remediation.
* Disclosure of testing and sampling methodologies used in an audit.

- Wayne

[1] http://www.webtrust.org/practitioner-qualifications/item64422.aspx

On Mon, Nov 19, 2018 at 8:25 AM Nick Pope via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> Restating my earlier offer we would welcome a clear statement of any
> concerns or wishes resulting from the discussions, on this or other related
> threads, against the measures already proposed in TS 119 403-2 and its
> parent standard.  We can then discuss this with the European stakeholders
> and see how we could best answer these concerns
>
> Nick
>
> On Friday, November 16, 2018 at 4:46:34 PM UTC, Wayne Thayer wrote:
> > On Thu, Nov 15, 2018 at 1:51 PM Ryan Sleevi <r...@sleevi.com> wrote:
> >
> ...
> >
> > In either case, I think we're missing normative guidance to objectively
> > distinguish poor judgement from policy violations.  To that end, I think
> > Nick's request for us to better define root program expectations is a
> > reasonable one. Analyzing current and past issues can certainly help us
> to
> > define these requirements.
>
>
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