In the Github document, which I'm using to track proposed language, I've
added "This applies to all non-technically constrained CA certificates,
including those that share the same key pair whether they are self-signed,
doppelgänger, reissued, cross-signed, or other roots."
https://github.com/BenWilson-Mozilla/pkipolicy/commit/5a3dd2e9d92ec689e08bf1cfa279121e2bb0478b
.

On Sun, Jan 24, 2021 at 3:12 PM Ben Wilson <bwil...@mozilla.com> wrote:

> As an alternative for this addition to MRSP section 5.3, please consider
> and comment on:
>
> Thus, the operator of a CA certificate trusted in Mozilla’s CA Certificate
> Program MUST disclose in the CCADB all non-technically constrained CA
> certificates they issue that chain up to that CA certificate trusted in
> Mozilla’s CA Certificate Program. This applies to all non-technically
> constrained CA certificates, including those that are self-signed,
> doppelgänger, reissued, or cross-signed.
>
>
> On Thu, Nov 12, 2020 at 11:54 AM Ben Wilson <bwil...@mozilla.com> wrote:
>
>> Jakob,
>>
>> On Thu, Nov 12, 2020 at 10:39 AM Jakob Bohm via dev-security-policy <
>> dev-security-policy@lists.mozilla.org> wrote:
>>
>>>
>>> How would that phrasing cover doppelgangers of intermediary SubCAs under
>>> an included root CA?
>>>
>>>
>>> To clarify, the title of section 5.3 is "Intermediate Certificates".
>> Also, both subsection (1) and (2) under the proposed amendment reference
>> "intermediate certificates" -  "(1) ...the Subject Distinguished Name in a
>> CA certificate or *intermediate certificate* that is in scope according
>> to section 1.1 of this Policy" and "(2)... corresponding Public Key is
>> encoded in the SubjectPublicKeyInfo of that CA certificate or *intermediate
>> certificate*." And finally, additional
>> language would try and make this clear by saying, "Thus, these
>> requirements also apply to so-called reissued/doppelganger CA certificates
>> (roots *and intermediates*) and to cross-certificates."
>>
>> I hope this answers your question.
>>
>> Sincerely,
>>
>> Ben
>>
>
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