Dear Wayne,

Please consider the fact that S/MIME is focused on "signature" Certificates which has different considerations than "authentication" Certificates. The baseline requirements (and their revocation requirements) are focused on "authentication" Certificates. I believe the revocation policies, at least for the CA Certificates, do not align well with S/MIME.

When a piece of data is "signed" (such as an e-mail), Relying Parties need to be able to verify the status of the signing Certificate _when the signature was created_. If the Issuing CA is revoked, it is no longer able to provide status information for that Certificate. If we think about the serial number issue, if a CA had to be revoked, status information for its issued Certificates would discontinue leading Relying Parties to have difficulties validating the existing signed e-mails that were valid when signed.

This might be something to consider more carefully.


Thank you,
Dimitris.


On 15/5/2019 3:25 π.μ., Wayne Thayer via dev-security-policy wrote:
On Tue, May 14, 2019 at 11:21 AM Kathleen Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

On 5/10/19 5:46 PM, Wayne Thayer wrote:
I've attempted to update section 6 to incorporate revocation requirements
for S/MIME certificates:


https://github.com/mozilla/pkipolicy/commit/15ad5b9180903b92b8f638c219740c0fb6ba0637
Note: since much of this language is copied directly from the BRs, if we
decide to adopt it, the policy will also need to comply with the Creative
Commons Attribution 4.0 International license used by the BRs.

I will greatly appreciate everyone's review and comments on this proposed
change.

The proposed changes look OK to me.

But I would also be fine with the new section 6.2 regarding revocation
of S/MIME certs just re-using the revocation text that we used to have
in our policy (which had been removed in an effort to remove redundancy
with the BRs).


https://github.com/mozilla/pkipolicy/blob/2.4.1/rootstore/policy.md#6-revocation


The 'reasons for revocation' from the old policy are very close to the BR
language I proposed. The main difference in my proposal is the inclusion of
deadlines by which certificates must be revoked (same as in the BRs). While
the BR deadlines have sometimes been challenging, I do feel that we're
better off to have them as our standard and handle exceptions as incidents,
so my preference is to stick with my proposal.
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