Thanks, Wayne.  I'll work on clarifying these points.

On Thu, Nov 11, 2021 at 1:10 PM Wayne Thayer <wtha...@gmail.com> wrote:

> Hi Ben,
>
> I'm confused by a few points on the wiki page:
> * Under 'Required Documentation', a key generation report is required.
> This makes sense in the case where a root CA is cross-signing a
> pre-existing CA key pair operated by a third party, but how is this
> intended to work if a subCA (including the key pair) is to be generated
> after the public discussion?
> * Bullet 4 of that section, titled 'Audits' presumably would be met in the
> case where the subordinate CA operator already has audits by providing
> those audit reports, but I don't understand where "a publishable statement
> or letter from an auditor" comes in to play or how that is different from
> an audit report?
>
> My confusion may stem from a lack of understanding of the process for
> standing up a new subordinate CA operator that doesn't have its own root.
>
> Thanks,
>
> Wayne
>
> On Thu, Nov 11, 2021 at 10:26 AM 'Corey Bonnell' via
> dev-security-policy@mozilla.org <dev-security-policy@mozilla.org> wrote:
>
>> > 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?
>>
>>
>>
>> One major downside of mandating a public discussion for the issuance of a
>> subCA certificate of the same type and class is one of agility: the
>> requirement for public discussion would be a disincentive for shorter subCA
>> certificate validity periods. Additionally, if revocation is required for a
>> subCA certificate, the requirement for a public discussion and approval for
>> its replacement would likely be an impediment to the timely revocation and
>> replacement process.
>>
>>
>>
>> Thanks,
>>
>> Corey
>>
>>
>>
>> *From:* Dimitris Zacharopoulos <ji...@it.auth.gr>
>> *Sent:* Thursday, November 11, 2021 11:47 AM
>> *To:* Corey Bonnell <corey.bonn...@digicert.com>; Ben Wilson <
>> bwil...@mozilla.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
>>
>>
>>
>> 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> <bwil...@mozilla.com>
>> *Sent:* Wednesday, November 10, 2021 5:46 PM
>> *To:* Corey Bonnell <corey.bonn...@digicert.com>
>> <corey.bonn...@digicert.com>
>> *Cc:* dev-secur...@mozilla.org <dev-security-policy@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)
>>
>>
>>
>> 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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