Hi Ben, I think the expectation can be clarified by amending the paragraph starting with “The process outlined herein applies to subCA operators not already in the Mozilla root program”. I suggest explicitly mentioning the three different types of trust, namely Email, (non-EV) Websites, and EV Websites and requiring the process be followed whenever an organization is to receive a subCA certificate that grants one or more of those technical capabilities that the organization did not have in the Mozilla root program. As a concrete proposal:
“The process outlined herein applies to organizations that do not control a Root or subCA certificate trusted by the Mozilla root program. Additionally, the process outlined herein applies to organizations that control a subCA or Root CA certificate in Mozilla’s root program but the new subCA certificate will grant technical capability for the issuance of additional types of certificates. Specifically, the process outlined herein MUST be followed when an organization does not control a subCA or Root CA certificate that grants capability to issue certificates of one or more of the following types and the new subCA certificate will grant such capability: S/MIME (Email trust bit), (DV/IV/OV) TLS Server Authentication (Websites trust bit), and/or EV TLS Server Authentication (Websites trust bit with EV-enablement).” Thanks, Corey From: Ben Wilson <bwil...@mozilla.com> Sent: Wednesday, November 10, 2021 5:46 PM To: Corey Bonnell <corey.bonn...@digicert.com> Cc: dev-secur...@mozilla.org <dev-security-policy@mozilla.org> Subject: Re: Policy 2.8: MRSP Issue #233: Wiki page documenting process for reviewing externally operated subordinate CAs Hi Corey, I think I'll disagree with your conclusion that there is no need to perform a review of Sub CA B for issuance of a new intermediate certificate to it with the serverAuth EKU. Let's assume that Root CA A already has both the websites bit and the email bit enabled by Mozilla. And assume that the review-and-comment process for Sub CA B focused only on the enablement of that CA for S/MIME certificate issuance. What if there had not been a thorough review of Sub CA B's Compliance Self Assessment (Required Documentation <https://wiki.mozilla.org/CA/Subordinate_CA_Checklist#Required_Documentation> #6) because much of the assessment applies only to server certificate issuance (i.e. what if the assessment had been filled with a lot of "N/A"s)? Then, the prior public discussion was insufficient.("Prior to public discussion, the root CA operator must confirm that it has verified all of the following information, which must be provided when the root CA operator starts the public discussion.") However, all of this might be different if the review of Sub CA B was thorough enough to cover server certificate issuance. I suppose I can make that more clear on the wiki page. I also welcome any suggestions. Thanks, Ben On Tue, Nov 9, 2021 at 3:30 PM Corey Bonnell <corey.bonn...@digicert.com <mailto:corey.bonn...@digicert.com> > wrote: Hi Ben, A scenario came to mind that may deserve further clarity in the text, so I wanted to raise it here. Suppose Root CA “A” kicks off the information-gathering and review process for Sub CA “B” (as outlined on the Wiki page) for the issuance of a subordinate CA certificate containing solely id-kp-emailProtection. The discussion ends favorably and Sub CA B is marked in CCADB as an “approved” organization. Some time later, Sub CA B wishes to obtain a subordinate certificate containing id-kp-serverAuth. Since this organization has previously been approved, according to the proposed language, there is no need to undergo the review and approval process again despite the difference in technical capability and audit requirements of the subordinate CAs. Is this an accurate read of the proposed language? Thanks, Corey From: dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org> <dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org> > On Behalf Of Ben Wilson Sent: Monday, November 1, 2021 2:58 PM To: dev-secur...@mozilla.org <mailto:dev-secur...@mozilla.org> <dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org> > Subject: Re: Policy 2.8: MRSP Issue #233: Wiki page documenting process for reviewing externally operated subordinate CAs I am proposing that we create a link in the MRSP to the process for review and approval of third-party externally operated CAs as indicated in the following commit: https://github.com/BenWilson-Mozilla/pkipolicy/commit/9efa9e73f6cff7924d1ed856eadd1902f31bd458 On Thu, Oct 28, 2021 at 2:56 PM Ben Wilson <bwil...@mozilla.com <mailto:bwil...@mozilla.com> > wrote: All, This email introduces another issue selected to be addressed in the next version of the Mozilla Root Store Policy (MSRP), version 2.8, to be published in 2022. (See <https://github.com/mozilla/pkipolicy/labels/2.8> https://github.com/mozilla/pkipolicy/labels/2.8) This is Github Issue #233 <https://github.com/mozilla/pkipolicy/issues/233> . I have re-published the wiki page for the process of reviewing and approving externally operated subordinate CAs. Here is the URL: https://wiki.mozilla.org/CA/Subordinate_CA_Checklist#Process_for_Review_and_Approval_of_Externally_Operated_Subordinate_CAs This issue is also related to an m.d.s.p. email that I sent and comments received with a subject line: Process for Considering Externally Operated Subordinate CAs <https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/AA5G1bzOwZQ/m/v4i0_wj9BAAJ> . Please provide any additional comments you may have regarding the review and approval process for externally operated subordinate CAs. 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