One more issue to clarify is what happens during the SubCA renewal process (and what "renewal" means), or issuance of another subCA to an organization that has already been approved for the same certificate type (server or email) and class (EV or not for server certificates).

Is it necessary to start a new discussion every time a new CA Certificate is about to be issued for that same type and class, or not ? Ben, would it make sense to add a new section to address this issue so there is no confusion?

Also, where would the information about the unconstrained external SubCAs that have passed public discussion and have been approved or denied be located?


Thanks,
Dimitris.

On 11/11/2021 3:21 μ.μ., 'Corey Bonnell' via dev-security-policy@mozilla.org wrote:

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> 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
    <dev-security-policy@mozilla.org> *On Behalf Of *Ben Wilson
    *Sent:* Monday, November 1, 2021 2:58 PM
    *To:* 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

    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>
    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.

        Thanks,

        Ben Wilson

        Mozilla Root Program Manager

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