Here are the proposed changes:
* Reinstate Mozilla's revocation requirements for S/MIME certificates:
https://github.com/mozilla/pkipolicy/commit/e6337bb76a4522da15aeb7c0862b6cc05d317814
(replacing the original 2.7 proposal with the older Root Store policy
requirements)
* Require revocation when a certificate violates our Root Store policy:
https://github.com/mozilla/pkipolicy/commit/fbe5c4f7b78bd4572632ce411a758eba1acf04ef
(note: I've already fixed the typo)

As always, I will appreciate everyone's review or and comments on this
proposal.

- Wayne

On Wed, Oct 2, 2019 at 4:00 PM Wayne Thayer <wtha...@mozilla.com> wrote:

> Thank you for the comments Dimitris. I think you make a valid point in
> general that S/MIME certificates are quite different from TLS certificates,
> and applying the BR rules to them might not be appropriate. I expect this
> to ultimately be sorted out by the CAB Forum's future S/MIME Working Group,
> but in the interim we still need some reasonable Mozilla policy. This leads
> me to conclude that the best solution might be to do as Kathleen suggested
> and reinstate the old Mozilla revocation requirements (prior to referencing
> the BRs) to apply to S/MIME certificates:
> https://github.com/mozilla/pkipolicy/blob/2.4.1/rootstore/policy.md#6-revocation
> The biggest change here from my earlier proposal would be that no
> revocation timeline would be specified.
>
> I also suggest that we add a requirement for both TLS and S/MIME
> certificates that states the CA must revoke a certificate that "does not
> comply with the version of this policy that was in effect at the time it
> was issued.". Currently, there is no hard requirement for CAs to revoke
> certificates that comply with the BRs but not with our own policy (e.g. use
> of the P-521 algorithm [1]).
>
> How do these changes sound to everyone?
>
> - Wayne
>
> [1]
> https://groups.google.com/d/msg/mozilla.dev.security.policy/4gs5pKqTeK8/_eJvekr1BgAJ
>
> On Fri, Jun 14, 2019 at 10:43 PM Dimitris Zacharopoulos via
> dev-security-policy <dev-security-policy@lists.mozilla.org> wrote:
>
>>
>> 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.
>> > _______________________________________________
>> > dev-security-policy mailing list
>> > dev-security-policy@lists.mozilla.org
>> > https://lists.mozilla.org/listinfo/dev-security-policy
>>
>> _______________________________________________
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>>
>
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