在 2019年1月15日星期二 UTC+8上午8:58:30,David E. Ross写道:
> On 1/14/2019 4:18 PM, Wayne Thayer wrote:
> > This request is for inclusion of the Government of Hong Kong, Hongkong
> > Post, Certizen Hongkong Post Root CA 3 trust anchor as documented in the
> > following bug: https://bugzilla.mozilla.org/show_bug.cgi?id=1464306
> > 
> > * BR Self Assessment is here:
> > https://bug1464306.bmoattachments.org/attachment.cgi?id=8980480
> > 
> > * Summary of Information Gathered and Verified:
> > https://bug1464306.bmoattachments.org/attachment.cgi?id=9004396
> > 
> > * Root Certificate Download URL:
> > https://bugzilla.mozilla.org/attachment.cgi?id=8980482
> > 
> > * CP/CPS:
> > CP: there is no CP
> > CPS: https://www.ecert.gov.hk/ev/e-Cert%20(Server)%20CPS-Eng-1.7.4.pdf
> > 
> > * This request is to include the root with the websites trust bit enabled
> > and EV treatment.
> > 
> > * EV Policy OID: 2.23.140.1.1
> > 
> > * Test Websites
> > https://valid-ev.ecert.gov.hk/
> > https://expired-ev.hongkongpost.gov.hk
> > https://revoked-ev.hongkongpost.gov.hk
> > 
> > * CRL URLs:
> > http://crl1.hongkongpost.gov.hk/crl/RootCA3ARL.crl
> > http://crl1.hongkongpost.gov.hk/crl/eCertESCA3-17CRL1.crl
> > 
> > * OCSP URL:
> > http://ocsp1.hongkongpost.gov.hk
> > 
> > * Audit: Annual audits are performed by PricewaterhouseCoopers Hong Kong
> > according to the WebTrust for CA, BR, and EV audit criteria.
> > WebTrust: https://www.cpacanada.ca/webtrustseal?sealid=2405
> > BR: https://www.cpacanada.ca/webtrustseal?sealid=2406
> > EV:
> > https://www.ecert.gov.hk/ev/Webtrust%20EV%20SSL%20Report%2020181219_FINAL%20(with%20Management%20Assertion%20Letter).pdf
> > 
> > I’ve reviewed the CPS, BR Self Assessment, and related information for
> > inclusion of the Certizen Hongkong Post Root CA 3 that is being tracked in
> > this bug and have the following comments:
> > 
> > ==Good==
> > This root is relatively new, has continuous BR audit coverage, and appears
> > to have only signed certificates for the required test websites.
> > 
> > ==Meh==
> > * The first EV audit was a point-in-time dated March 31, 2018 [1]. Given
> > that EV certificates for the test sites were issued in May 2018, one can
> > argue that EVGL section 17.4 required a period-of-time audit to have been
> > completed in October rather than December as was the case. However, it has
> > been common for CAs to argue that certificates for test websites don’t
> > count and I have not yet published clear guidance on this issue.
> > * There is no document referenced as a CP. Hongkong Post says that the
> > document is a combined CP/CPS.
> > * In 2016, it was discovered that Hongkong Post was issuing SHA-1
> > certificates with non-random serial numbers that could be used for TLS in
> > Firefox [2] [3]. The problem was resolved by adding the problematic
> > intermediate certificate to OneCRL.
> > * The CPS permits external RAs, but according to Appendix E, there are none
> > at present. I would prefer that the CPS clearly state that domain
> > validation functions are never delegated.
> > * Hongkong Post has attached unpublished versions 2 and 3 of their CPS to
> > the bug that differ from the published versions 2 and 3 in their
> > repository. The latest version “4” is marked as a “Pre-production CPS”.
> > They state that “…we cannot issue EV certificate to customers until
> > Mozilla, or at least some other root certificate programs, have granted EV
> > treatment to our root certificate. So, we do not yet publish the CPS in
> > order to avoid confusion to customers.”
> > 
> > ==Bad==
> > * Fairly recent misissuance under the currently included Hong Kong Post
> > Root CA 1: O and OU fields too long [4]. These certificates have all been
> > revoked, but no incident report was ever filed.
> > * CPS section 3.4 indicates that certificates may be suspended. This would
> > violate BR 4.9.13. This has been corrected in the “Pre-production” CPS but
> > not the current CPS for their existing root [5].
> > * CPS section 4.9.1 does not appear to include all the revocation reasons
> > required by BR 4.9.1.1. This has been corrected in the “Pre-production” CPS
> > but not the current CPS for their existing root [5].
> > 
> > This begins the 3-week comment period for this request [6].
> > 
> > I will greatly appreciate your thoughtful and constructive feedback on the
> > acceptance of this root into the Mozilla CA program.
> > 
> > - Wayne
> > 
> > [1] https://bug1464306.bmoattachments.org/attachment.cgi?id=8980478
> > [2]
> > https://groups.google.com/forum/#!msg/mozilla.dev.security.policy/Ng99HcqhZtI/bkcimGlECAAJ
> > [3] https://bugzilla.mozilla.org/show_bug.cgi?id=1267332
> > [4]
> > https://crt.sh/?caid=7319&opt=cablint,zlint,x509lint&minNotBefore=2017-01-01
> > [5] https://www.ecert.gov.hk/product/cps/ecert/img/server_cps_en3.pdf
> > [6] https://wiki.mozilla.org/CA/Application_Process
> > 
> 
> I would think that lack of a CP alone would disqualify this root.

I think it is ok to combine CP/CPS document instead of maintaining two separate 
documents. The following is from webtrust for ca 2.1:

Together, the CP and CPS represent a CA’s business practice disclosures. It is 
leading practice for the CP at a minimum be publically available to relying 
parties, and most CAs also make their CPS publically available. Many CAs also 
publish a combined CP/CPS document instead of maintaining two separate 
documents.

> Furthermore, the the "Meh" issues should be resolved before approval.
> 
> -- 
> David E. Ross
> 
> Trump again proves he is a major source of fake news.  He wants
> to cut off disaster funds to repair the damage caused by the
> Woolsey Fire in southern California because he claims the state
> fails to manage its forests properly.  The Woolsey Fire was NOT
> a forest fire.  Starting in an industrial tract, it did not burn
> through any forests.
> 
> See <http://www.rossde.com/fire.html>.

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