This issue is now documented in
https://bugzilla.mozilla.org/show_bug.cgi?id=1625767

On Tue, Mar 24, 2020 at 12:29 PM Sándor dr. Szőke via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

>
> Investigation of the situation:
>
> 2009-03-06
>         Microsec Ltd. issued the following root certificate:
>         - Microsec e-Szigno Root CA 2009
>         Expiry date: 2038-01-18
>
> 2009-03-09
>         Microsec Ltd. issued the following subordinate CA certificates:
>         - Advanced Class 2 e-Szigno CA 2009
>         - Advanced Class 3 e-Szigno CA 2009
>         - Advanced Pseudonymous e-Szigno CA 2009
>         - Qualified Pseudonymous e-Szigno CA 2009
>         - Qualified e-Szigno CA 2009
>
>         Expiry date of each of these certificates: ‎2038-01-17
>
>
> 2009-06-16
>         Microsec reissued the following root certificate:
>         - Microsec e-Szigno Root CA 2009
>         Expiry date: 2029-12-30
>         In the certificate the following fields were changed: validity
> notBefore and notAfter dates, and the certificatePolicies extension.
>
>         Microsec reissued the following subordinate CA certificates:
>         - Advanced Class 2 e-Szigno CA 2009
>         - Advanced Class 3 e-Szigno CA 2009
>         - Advanced Pseudonymous e-Szigno CA 2009
>         - Qualified Pseudonymous e-Szigno CA 2009
>         - Qualified e-Szigno CA 2009
>
>         Expiry date of each of these certificates (aligned with the new
> root): ‎2029-12-29
>         In the certificates the following fields were changed: validity
> notBefore and notAfter dates, and the certificatePolicies extension.
>
>
> 2009-12-02
>         Microsec reissued the following root certificate:
>         - Microsec e-Szigno Root CA 2009
>         Expiry date was unchanged: 2029-12-30
>         The certificatePolicies extension was dropped from the
> certificate, and the place of the keyUsage extension changed within the
> ASN.1 structure.
>
>         Microsec reissued the following subordinate CA certificates:
>         - Advanced Class 2 e-Szigno CA 2009
>         - Advanced Class 3 e-Szigno CA 2009
>         - Advanced Pseudonymous e-Szigno CA 2009
>         - Qualified Pseudonymous e-Szigno CA 2009
>         - Qualified e-Szigno CA 2009
>
>         In the certificates the validity notBefore date changed to the
> issuance date, the certificatePolicies extension changed to anyPolicy, and
> the URL pointing to the location of CPS documents changed to a uniform
> value for qualified and non-qualified certificates.
>
>
>         In summary, all above certificates were reissued by Microsec two
> times during 2009. In these two cases each certificate was reissued with an
> unchanged public key and unchanged Subject DN as compared to the previous
> corresponding certificate, while some other fields were changed. The CA
> certificates were published (apart from the website) through the Microsec
> e-Szigno signature creation and validation application, and were (may have
> been) also published in the trusted certificate stores of other software.
>
>         The CA certificates were primarily intended for electronic
> signatures. It is necessary to be able to validate digital signatures
> chaining up to these CAs in the long term (50 years). Since electronic
> signature (end user) certificates only contain the Subject DN of the issuer
> CA, the reissued (doppelganger) subordinate CA certificates with the same
> Subject DN and key are equally suitable for certificate chain building. As
> a consequence, revocation of some subordinate CA certificates might cause
> validation errors (false negatives) in some signature validation
> applications, therefore, Microsec maintained all versions of the CA
> certificates as valid.
>         This solution worked without problems in the creation and
> validation of signatures, and Microsec has not received any error reports
> in relation to this throughout the years.
>         Microsec has always published and promoted the use of the latest
> version of the CA certificates, but could not prevent the use of the
> earlier versions.
>
>
> 2016-11
>         Having set up the CCADB, Mozilla introduced more and more
> stringent checks, and earlier versions of some of the CA certificates were
> added to the database.
>         Upon the notification from Mozilla, Microsec investigated the
> situation, and requested to maintain the validity of the affected CA
> certificates due to reasons explained above. Mozilla temporarily approved
> to keep all CA certificate verions valid.
>
>
> 2019-11
>         In relation to the improvement of the CCADB system Mozilla
> launched automated tools for audit letter validation (ALV). These controls
> require each subordinate CA certificate in CCADB to be included in one of
> the audit letters. The automatic checking is based on the SHA-256
> fingerprint of the certificate.
>
>         During the validation of the Microsec audit letters the ALV tool
> found 9 discrepancies, which can be categorized in the following types:
>
> 1.      Formatting problem in the audit letter (5 out of 9)
>         In the audit letters issued near the beginning of 2019 the SHA-256
> fingerprint of some certificates were split in two parts by a page break
> inside the table cell, so the ALV tool was unable to parse the SHA-256
> value. The affected certificates were flagged with ALV failures.
>         Microsec contacted its auditor about this problem. As a result,
> the new audit letters issued near the end of 2019 did not have this
> problem, the ALV tool could parse all certificate fingerprints, so the ALV
> failures disappeared.
>
>
> 2.      Subordinate CA certificates without audit letters (4 out of 9)
>         The earlier versions of the above mentioned doppelganger
> subordinate CA certificates were not included in the audit letters (always
> the latest certificate fingerpring was included), so these (4 cases) were
> flagged as ALV failures.
>         Microsec contacted Mozilla again in this matter, referring to the
> earlier approval. Mozilla answered that the approval granted 3 years before
> could not remain valid indefinitely, so considering the recent changes in
> the automated checks, it was required that each valid subordinate CA
> certificate should be covered in an audit letter.
>         Microsec had two options:
>         - revoke the earlier versions of the affected (doppelganger)
> subordinate CA certificates, or
>         - include them in the scope of the audit and have them appear in
> the audit letter.
>         As 10 years have elapsed since the deprecation of those
> certificates and Microsec did not want to have them added to the audit
> letters, Microsec decided to revoke the certificates in question.
>
> 2019-11-29
>         All earlier versions of the subordinate CA certificates were
> revoked.
>         The revocation caused errors in the systems of some clients, but
> all of those problems were successfully solved by changing the software
> configuration.
>         Microsec registered the revocations in the CCADB system, and the
> corresponding ALV failures disappeared.
>
>
> 3.      Doppelganger root certificate
>         CCADB contains one of the earlier versions of the "Microsec
> e-Szigno Root CA 2009" certificate, which is now deprecated and not used.
> Since root certificates cannot be revoked, following a discussion with
> Mozilla experts Microsec requested the auditor to include both certificates
> of the root CA in the audit letter.
>         The latest audit attestation contains both root CA certificates,
> so the corresponding ALV failures disappeared.
>
>         As a result, the CCADB currently displays no ALV failures.
>
> 2020-03-17
>         In order to clarify the situation, Microsec made an assessment of
> all affected certificates.
>
>         As a result of the in-depth investigation, Microsec has determined
> that 7 of the subordinate certificates, which have been issued from the
> "Microsec e-Szigno Root CA 2009" root and have already been revoked, are
> not in the current CCADB registry.
>         It was also found that the unused version of the "Microsec
> e-Szigno Root CA 2009" Root Certificate of 2009-03-06 is not in the CCADB
> registry either.
>
> 202-03-24
>         Microsec uploaded the missing subordinate certificates to the
> CCADB registry.
>
>         Microsec uploaded also the "Microsec e-Szigno Root CA 2009" Root
> Certificate to the CCADB registry as a doppelganger subordinate certificate.
>         This will result in an ALV failure (reporting lack of
> certification) as the root certificate cannot be revoked and it is not
> included in the current audit attestation letters.
>         To resolve this warning, Microsec shall request a new audit report
> from the auditor that includes this third root certificate too.
>         Until this new audit attestation is uploaded, considering the full
> transparency provided by the above detailed investigation and submissions,
> Microsec requests Mozilla to disregard this temporary ALV failure.
>
>
>
>
>
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