On Mon, 4 Feb 2019 at 18:06, Ryan Sleevi <r...@sleevi.com> wrote:
>
> On Mon, Feb 4, 2019 at 10:46 AM Matthias van de Meent via dev-security-policy 
> <dev-security-policy@lists.mozilla.org> wrote:
>>
>> Hi,
>>
>> Today we've bought a wildcard certificate [0] for our cofano.io domain
>> from Sectigo (previously ComodoCA) via a reseller. Our CAA policy
>> describes that only "comodoca.com" can issue wildcards. The
>> certificate has been issued and signed by Sectigo's 'new' intermediate
>> and root [1] [2].
>>
>> My question is the following: Was Sectigo allowed to sign the
>> certificate using their Sectigo (not ComodoCA) keys, while my CAA
>> record specifies 'issuewild "comodoca.com"'?
>
>
> Yes
>
>>
>> I.E. How should a CA name
>> change be reflected in ( CAA ) conformance? Especially since the
>> Sectigo CPS [3] still only specifies Comodo as their issuer name,
>> which conflicts with the CN/O of the signing certificate [1].
>
>
> There's zero requirement about any such mapping.
>
> The Baseline Requirements, Section 2.2, requires that CAs disclose their 
> policies and respected domains for their CAA policy.
>
> Section 3.2.2.8 places more requirements, largely around the 
> processing/validation model. To the question of domain names is not touched.
>
> Thus, a CA can disclose in their CP/CPS many domains, including those of 
> affiliated or non-affiliated CAs. Provided that this is disclosed in their 
> CP/CPS, and their exception process is clearly documented for domains not in 
> that enumerated list, then they're complying.
>
> Sectigo's CP/CPS discloses that they'll issue for comodoca.com (4.2 of their 
> CPS - https://sectigo.com/uploads/files/Comodo-CA-CPS-4-2.pdf ; section 
> 4.2.4), therefore they've met the requirements.

I agree that sectigo hosts a CPS which meets the requirements for them
to issue a certificate for the website. The issue is different here,
though.

The apparent signee (ComodoCA/Sectigo) has issued their CPS here
(https://sectigo.com/legal , https://www.comodoca.com/en-us/legal/ ),
latest version both being 4.2, which mentions (in section 7.1.1
<Certificate Profile, Certificate Versions>) that the certificates
will be issued according based on the CPS, Appendix C, which only
includes 'O=Comodo Limited'-, 'O=Comodo CA Limited'- and 'O=The
USERTRUST Network'-issuer certificates.

As the signee of my certificate is not included in any way or form in
the CPS of neither ComodoCA nor Sectigo, this would _not_ qualify as a
certificate signed according to ComodoCAs nor Sectigos CPS (using a
strict reading), and as such this would be an indication of a rogue
intermediate certificate authority (if that is the correct term).

Please advise
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