On Thursday, February 25, 2021 at 2:30:52 PM UTC-5, bwi...@mozilla.com wrote:
> I haven't seen any response to my question about whether there is still a 
> concern over the language "as evidenced by a Qualified Auditor's key 
> destruction report". 
> I did add "This cradle-to-grave audit requirement applies equally to 
> subordinate CAs as it does to root CAs" to address the scenarios that were 
> raised. 
> So I am going to assume that this issue is resolved and that we can move 
> this proposed change forward. 
> See 
> https://github.com/BenWilson-Mozilla/pkipolicy/commit/c8bdb949020634b1f8fa31bc060229c600fe6f9d

Ben, sorry for the late input.

We are onboard with the cradle-to-grave audit as we have experience auditing 
non-functioning CAs before they go into production and after they have stopped 
issuing certificates. However, I think there might be an issue in the 
requirement with the start and stop time of cradle-to-grave. 

At the beginning, I think that CAs will generate one or many keys, but will not 
assign them to CAs. The gap period could be days to years. Since the 
requirement says "from the time of CA key pair generation", do we want an audit 
of an unassigned key? Or should the audit start once the key has been assigned 
and the CA certificate has been generated?

At the end, subordinate CA certificate(s) may be revoked or may expire. Once 
the certificate(s) are revoked or expired, is this a reasonable time to stop 
auditing the CA as trust has been removed? Of course if the certificates are 
not revoked or expired, then all copies of the keys should be destroyed to stop 
the audit. However, I think the best practice should be that certificates 
should be revoked/expired at time of key destruction.
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