I feel like this item needs to be further discussed...

1) section 1.1 of Mozilla's Root Store Policy (MRSP) 
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#11-scope>
 
limits the scope of the policy to "intermediate certificates which are 
technically capable of issuing working server or email certificates". So my 
understanding is that the proposed changes would mean that all intermediate 
certificates which are technically capable of issuing working server or 
email certificates must be disclosed in the CCADB, even if they are name 
constrained. And the proposed changes would NOT mean that intermediate 
certificates would need to be disclosed in the CCADB when they contain an 
Extended Key Usage (EKU) extension which does not contain any of these 
KeyPurposeIds: anyExtendedKeyUsage, id-kp-serverAuth, 
id-kp-emailProtection.  
Correct?

2) Just wondering... How do you all think that requiring disclosure of 
technically-constrained intermediate certs in the CCADB improves security 
for end-users?



> I have made an attempt to address this further with some commits in my 
> GitHub repository:
>
>
> https://github.com/mozilla/pkipolicy/compare/1829373903c8d58246c781ee11ea77d6d386985a...
> e6550dba22ed38ac6bdd33677a8bf3d2f00e75de
>
>
3) regarding the proposed change in the first paragraph of section 5.3 from
"Certificate Program MUST be operated in accordance with this policy and 
MUST either be technically constrained or be publicly disclosed and 
audited."
to
"Certificate Program MUST be operated in accordance with this policy and 
MUST either be technically constrained or be audited."

My interpretation of the original sentence was: "MUST either be technically 
constrained or (be publicly disclosed and audited)."
meaning that 3rd-party audit statements would have to be provided.
I do NOT interpret it as meaning that technically-constrained intermediate 
certificates do not have to be audited at all. The BRs provide specific 
requirements for the oversight of technically-constrained intermediate 
certificates that I view as the minimum oversight that should be done for 
such intermediate certificates.

Therefore, I think that first paragraph should be changed to:
All certificates that are capable of being used to issue new certificates 
which are technically capable of issuing working server or email 
certificates and that directly or transitively chain to a CA certificate 
included in Mozilla’s CA Certificate Program MUST be operated in accordance 
with this policy and MUST be publicly disclosed in the CCADB.


4) Regarding these changes:
> Move the 4th paragraph in MRSP § 5.3 to the first paragraph of § 5.3.2. 
> Move content from the second bullet in MRSP § 5.3.2 to the first 
paragraph and eliminate the bulleted list.

I think the new text of section 5.3.2  looks OK, except

4.a) Move this to its own paragraph: 
Name Constrained CA certificates that were exempt from disclosure in 
previous versions of this policy MUST be disclosed in the CCADB prior to 
July 1, 2022.

4.b) We CANNOT delete the sentence, "All disclosure MUST be made freely 
available..."
We must keep that text, especially for audit statements. So keep this text 
as a separate paragraph:

All disclosure MUST be made freely available and without additional 
requirements, including, but not limited to, registration, legal 
agreements, or restrictions on redistribution of the certificates in whole 
or in part.

Thanks,
Kathleen

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