On 01/10/2019 00:45, Wayne Thayer via dev-security-policy wrote:
> I've initiated a CAB Forum ballot [1] to resolve the inconsistency that Rob
> identified.

Thanks Wayne.  I've offered to endorse.

> I also want to acknowledge the feedback from Google on the timing of this.
> I can appreciate the framing of this as a new policy that's been added
> without due process, but I view this as a clarification of existing
> requirements.

I view [4] as new policy that's been added without due process.  I would 
have preferred to see your CABForum ballot [1] resolve this in the BRs 
first, so that CAs weren't faced with conflicting requirements.

> Some CAs have already been held accountable for this requirement [2]
> and some that have been paying close attention adhere to
> it. Others were struggling to determine what to do. Under these
> circumstances, it made no sense to me to roll back the policy, so the only
> reasonable course was to clarify it in favor of the consensus that emerged
> from this thread.

Some CAs (including Sectigo, as I mentioned in an earlier message) are 
currently compliant with (quoting you [1])...
   "During a lengthy discussion on the mozilla.dev.security.policy forum,
    it was discovered that BR section 4.9.10 combined with BR
    section 7.1.2.5 prevents a CA from responding “good” for a
    precertificate." [1]

...but are not compliant with [4].

If/when your CABForum ballot [1] passes and (after the IPR period) takes 
effect, it will become possible for CAs to comply with [4] without 
falling out of compliance with the root program policies of Apple, 
Microsoft, etc, which incorporate the BRs but don't have a BR policy 
override equivalent to [4]).  Until then, what does Mozilla expect CAs 
to do?

> I'm still open to making changes to our "required practice" on
> precertificates, but having caught up on the thread I don't think any
> further changes are necessary.

I propose that you update [4] to say that Mozilla won't treat 
non-compliance with [4] as an "incident" whilst it remains the case that 
the BRs are inconsistent with [4].

> - Wayne
> 
> [1] https://cabforum.org/pipermail/servercert-wg/2019-September/001111.html
> [2] https://bugzilla.mozilla.org/show_bug.cgi?id=1551390
> [3]
> https://groups.google.com/d/msg/mozilla.dev.security.policy/PYIAoh6W6x0/R0gr1d6wBQAJ

[4] 
https://wiki.mozilla.org/CA/Required_or_Recommended_Practices#Precertificates

-- 
Rob Stradling
Senior Research & Development Scientist
Sectigo Limited

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