Hi Ben,
A few follow-up questions and comments:

1) What are the expectations regarding availability for such CRLs? Do the 
availability requirements in BR 4.10.2 stand for these CRLs even if such CRL 
pointers are not encoded in end-entity certificates?
2) What is the expectation for populating the CRLDP in end-entity S/MIME 
certificates? If no change in policy for S/MIME end-entity certificates is 
desired, then I think the text should be further qualified with "CAs SHOULD 
place the URL for the associated CRL within the crlDistributionPoints extension 
of issued *server* certificates".

Thanks,
Corey

On Thursday, January 7, 2021 at 8:00:46 PM UTC-5, Ben Wilson wrote:
> This is the last issue that I have marked for discussion in relation to 
> version 2.7.1 of the Mozilla Root Store Policy 
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>.
>  
> It is identified and discussed in GitHub Issue #218 
> <https://github.com/mozilla/pkipolicy/issues/218> for the MRSP. 
> 
> I will soon update everyone on the status of the other 13 discussion items 
> already presented, as some of them are in need of revision based on 
> comments received thus far. 
> 
> While subsection (b) of section 7.1.2.3 of the Baseline Requirements makes 
> a cRLDistributionPoint (CDP) in end entity certificates optional, Mozilla 
> still desires that CRL-based revocation information be available because 
> CRLite uses CRLs to construct its revocation filters. (Apple also uses 
> such CRL information in its certificate validation processes and, as I 
> understand, is making a similar request of CAs with respect to the new 
> CCADB field, discussed below.) 
> 
> While all such CRL information is needed, large CRLs are disfavored because 
> of the time they take to download and process. Thus, CAs shard, partition, 
> or "scope" their CRLs into smaller chunks. Section 5 of RFC 5280 explains, 
> "Each CRL has a particular scope. The CRL scope is the set of certificates 
> that could appear on a given CRL. … A complete CRL lists all unexpired 
> certificates, within its scope, that have been revoked for one of the 
> revocation reasons covered by the CRL scope. A *full and complete CRL* 
> lists all unexpired certificates issued by a CA that have been revoked for 
> any reason." (Emphasis added.) 
> 
> There is a new field in the CCADB for CAs to include information needed for 
> browsers or others to construct a "full and complete CRL", i.e. to gather 
> information from CAs that don't include the CRL path to their "full and 
> complete CRL" in end entity certificates they issue. This new CCADB field 
> is called "Full CRL Issued By This CA" and is located under the heading 
> "Pertaining to Certificates Issued by this CA." Rather than condition the 
> requirement that CAs fill in this information in the CCADB only when they 
> don't include a CDP to a full and complete CRL, I propose that this new 
> CCADB field be populated in all situations where the CA is enabled for 
> server certificate issuance. In cases where the CA shards or partitions its 
> CRL, the CA must provide a JSON-based list of CRLs that when combined are 
> the equivalent of the full and complete CRL. 
> 
> Proposed language to add to section 6 of the Mozilla Root Store Policy is 
> as follows: 
> 
> *CAs SHOULD place the URL for the associated CRL within the 
> crlDistributionPoints extension of issued certificates. A CA MAY omit the 
> crlDistributionPoint extension, if permitted by applicable requirements and 
> policies, such as the Baseline Requirements. * 
> 
> *A CA technically capable of issuing server certificates MUST ensure that 
> the CCADB field "Full CRL Issued By This CA" contains either the URL for 
> the full and complete CRL or the URL for the JSON file containing all URLs 
> for CRLs that when combined are the equivalent of the full and complete CRL* 
> . 
> 
> 
> I look forward to your comments and suggestions. 
> 
> Ben
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