Hi Clint,

The content of your email, the blog post and the Apple root policy all say
something a little different and may leave some room for interpretation by
the CAs.  As it stands, things are a bit confused.  Here's why:

Your mail is a little light on the details.  While you say this is an
"upcoming change" to the Root Program you say certificates "will need to
have a lifetime of no more than 398 days".  The "will need to have" is
really weak.  If this is a hard requirement then I would say something
stronger like: "The Apple Root Program requires (as of Sept 1) CAs to issue
certificates with validity period not to exceed a total life time of 398
days under roots in the Apple root program.  Any certificates issued under a
Root in the Apple root program will be considered a violation of the Apple
Root policy" (or something like that).  Done, everyone knows exactly what
you mean.

The article you posted does not mention Apple Root program or policy and it
more or less a general statement without any context.   "TLS server
certificates issued on or after September 1, 2020 00:00 GMT/UTC must not
have a validity period greater than 398 days."  If Connections (presumably
from Safari browser or Apple apps) are attempted, then "This might cause
network and app failures and prevent websites from loading".  There is
nothing indicating this is an Apple Root policy requirement or that CAs need
to take note, only that if an Apple endpoint encounters one of these
non-compliant certificates, the connection may/will fail.

Your root policy: Obviously there is nothing here about this new change, and
if this is "the" Apple root policy, I'd recommend getting that updated with
a clear statement of this requirement and what happens if a certificate is
issued with a lifetime outside of this duration.  Chrome has a policy that
it will not trust certificates that are not compliant with their CT policy,
but it's not a Root policy.  Is this how Apple views their policy, or is it
a Root policy and any non-compliance is considered a mis-issuance by Apple?
The various statements lead me back and fourth between those 2
interpretations.

I think it's important that this be clearly stated, and I dislike formal
root policies being documented only in email threads.  How would a new CA
know this is a requirement without going through years of archived email on
multiple lists?

By the way, there is no reporting process outlined in the event that
something in your policy is violated.  How should violations be reported and
tracked?

Thanks!

Doug

-----Original Message-----
From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> On
Behalf Of Clint Wilson via dev-security-policy
Sent: Tuesday, March 3, 2020 2:55 PM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: About upcoming limits on trusted certificates

Hello all,

I wanted to inform this community of an upcoming change to the Apple Root
Program. 
SSL/TLS certificates issued on or after September 1, 2020 will need to have
a total lifetime of no more than 398 days. This change will be put in place
in a future release of iOS, macOS, iPadOS, watchOS, and tvOS for
default-trusted TLS certificates (i.e. the Roots that come preinstalled on
the above OSes).

For additional information, please see
https://support.apple.com/en-us/HT211025.

Thank you!
-Clint
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