On Tue, Jul 9, 2019 at 5:50 PM Kathleen Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> All,
>
> There is some confusion about disclosure of new intermediate certs that
> are issued to subordinate CAs with currently valid audit statements.
>
> Section 5.3.2 of Mozilla's Root Store Policy says: "If the CA has a
> currently valid audit report at the time of creation of the certificate,
> then the new certificate MUST appear on the CA's next periodic audit
> reports."
>
> I think it is reasonable to assume that the same policy applies to
> subordinate CAs, such that if the subordinate CA has a currently valid
> audit report at the time of creation of a new intermediate certificate,
> then the new certificate MUST appear on the subordinate CA's next
> periodic audit reports.
>
> The confusion is about how to disclose such a new intermediate
> certificate in the CCADB.
>
> I propose that to handle this situation, the CA may enter the
> subordinate CA's current audit statements and use the Public Comment
> field to indicate that the new certificate will be included in the next
> audit statements. (Also, a quick comparison of the cert's Valid-From
> date and the audit period dates will indicate this situation.)
>
> Please let me know if you foresee any problems with this approach.
>

That aligns with past discussions [1][2], which resulted in similar
uncontroversial proposals [3]. Wayne previously discussed the lifecycle of
certificates during past CA/Browser Forum F2Fs [4][5]. With respect to [5],
Wayne proposed the uncontroversial "Change #3" for the alignment of audit
reports, and this would similarly align the disclosure.

This is particularly important to be harmonized, given reports like [6],
which provide an important signal to the community about the entities
involved with issuance.

Note that if the same policies do not apply to the new sub-CA, it has
seemed uncontroversial that some form of new audit is required. Is that
consistent with your understanding as well?

[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/CAaC2a2HMiQ/IKimeW4NBgAJ
[2]
https://groups.google.com/d/msg/mozilla.dev.security.policy/v8-V2D957tU/BtogJ3rECQAJ
[3] https://blog.mozilla.org/security/2018/07/02/root-store-policy-updated/
[4]
https://cabforum.org/2018/10/18/minutes-for-ca-browser-forum-f2f-meeting-45-shanghai-17-18-october-2018/#28-Audit-requirements-over-the-lifecycle-of-a-root
[5]
https://cabforum.org/2019/05/03/minutes-for-ca-browser-forum-f2f-meeting-46-cupertino-12-14-march-2019/#Audit-requirements-over-the-lifecycle-of-a-Root-CA
[6]
https://groups.google.com/d/msg/mozilla.dev.security.policy/7bLbgXTf5Ng/l8nmVfzEAwAJ
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