Dear MDSP community,

As you are aware from past discussions on this list, there has been a
concern about the impact of COVID-19 on CA operations.  COVID-19 continues
to impact certain areas of the world more severely than others. For
example, there has been a recent resurgence of COVID-19 in Japan.[1]  Globally,
COVID-19 has not leveled out.[2]

Recently at least one CA has expressed concern about Action 3 of Mozilla's
January 2020 CA Communication [3] and enforcement of Section 5.2 of
Mozilla’s Root Store Policy, which provide that as of 1-July-2020,
end-entity certificates MUST include an EKU extension containing
KeyPurposeId(s) describing the intended usage(s) of the certificate, and
the EKU extension MUST NOT contain the KeyPurposeId anyExtendedKeyUsage.
See [4].

Some CAs (and their customers) located in Japan, the U.S., and elsewhere
are dealing with new priorities that were not apparent back in January.  Some
have had to reorganize to deal with reduced staff and reallocate resources,
while other companies have modified their schedules to delay changes that
might cause instability.[5], [6]

For some parties, the benefit of a 3-month delay (to 1-October-2020) in
enforcement of Mozilla’s EKU requirement may result in more flexibility,
resilience and secure operations.

Several options are being considered:

1.       Require that a CA request an extension, to be submitted on
Bugzilla and flagged as “covid-19”, similar to audit delays [7] AND

a.       Not require an incident report, OR

b.       Require an incident report

2.       Grant a blanket 3-month extension and not require revocation of
certificates that do not comply

3.       Replace July 1 with October 1 in section 5.2 of the Mozilla Root
Store Policy and publish a new version

4.       Recognize broader exceptions for COVID-19 issues, e.g. enlarge the
scope of the delayed-audit approach to include other non-conformities/other
issues and not require immediate certificate revocations

I look forward to hearing your opinions and suggestions.

Sincerely yours,

Ben Wilson

Endnotes:

[1]  https://apnews.com/9140ddd7283d534d8464778d9c4bd92a

[2]
https://ourworldindata.org/coronavirus#what-is-the-total-number-of-confirmed-cases

[3]
https://ccadb-public.secure.force.com/mozillacommunications/CACommResponsesOnlyReport?CommunicationId=a051J00003waNOW&QuestionId=Q00086,Q00087,Q00097


[4]
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#52-forbidden-and-required-practices

[5]  https://docs.microsoft.com/en-us/security/trusted-root/2020/april2020

[6]
https://blog.chromium.org/2020/04/temporarily-rolling-back-samesite.html

[7]  https://wiki.mozilla.org/CA/Audit_Statements#Audit_Delay
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