Hi Rob,

It’s possible, but not guaranteed at this moment, that the policy update will 
be published prior to October 1st, however an official communication was sent 
to CAs (earlier this month) participating in the Apple Root Program clarifying 
interpretation of this requirement. If that is insufficient in the interim in 
the view of CAs or other interested parties to be comfortable with their own 
compliance, I would appreciate that feedback and will certainly work with any 
impacted CAs in this regard.

Thank you!
-Clint

> On Sep 21, 2022, at 1:21 PM, Rob Stradling <r...@sectigo.com> wrote:
> 
> AIUI, the latest published version of a root store policy always takes 
> precedence over (1) draft updates to that policy, (2) language proposed for 
> public discussion by the policy's owner, and (3) expressions of intent by the 
> policy's owner that are at odds with the latest published policy language.  
> With that in mind...
> 
> Clint, thanks for confirming that Ben's proposed language matches the intent 
> of the similar Apple Root Program requirement.  Do you plan to update 
> https://www.apple.com/certificateauthority/ca_program.html 
> <https://www.apple.com/certificateauthority/ca_program.html> before October 
> 1st, so that the Apple Root Program's effective policy for CRL URL 
> disclosures matches your intent?
> The current language - "for each included CA Certificate and each CA 
> Certificate chaining up to an included CA Certificate in the Apple Root 
> Program" - leaves no room for a "before the CA signs certificates" carve-out, 
> and there's also no permission for any delay between the issuance of a 
> Subordinate CA Certificate and the disclosure of its CRL URL(s).
> 
> Ben, thanks for proposing some language for discussion.  Do you plan to 
> (quoting you) "modify MRSP section 4.1 to more clearly indicate when full 
> CRLs need to be added to the CCADB" before October 1st?
> The current language in 
> https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#41-additional-requirements
>  
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#41-additional-requirements>
>  leaves no room for a "before the CA signs certificates" carve-out, and 
> there's no permission for any delay between the issuance of a Subordinate CA 
> Certificate and the disclosure of its CRL URL(s).
> 
> Alternatively...
> If Mozilla's and Apple's intended policies are aligned on these matters, 
> would it be better to add the language to 
> https://www.ccadb.org/policy#4-intermediate-certificates 
> <https://www.ccadb.org/policy#4-intermediate-certificates> and then update 
> both the MRSP and https://www.apple.com/certificateauthority/ca_program.html 
> <https://www.apple.com/certificateauthority/ca_program.html> to defer to the 
> CCADB Policy?
> 
> From: 'Clint Wilson' via dev-security-policy@mozilla.org
> Sent: Thursday, August 25, 2022 18:31
> To: Ben Wilson
> Cc: Christophe Bonjean; MDSP
> Subject: Re: CRL Issuance Frequency for non-published CRLs
> 
> Hi all,
> 
> FWIW, the below language also matches the intent of the similar Apple Root 
> Program requirement.
> 
> Thanks,
> -Clint
> 
>> On Aug 25, 2022, at 10:20 AM, Ben Wilson <bwil...@mozilla.com 
>> <mailto:bwil...@mozilla.com>> wrote:
>> 
>> Hi Christophe,
>> 
>> We do want to maintain some flexibility here and to mirror current practices 
>> without creating new unnecessary requirements.  We could modify MRSP section 
>> 4.1 to more clearly indicate when full CRLs need to be added to the CCADB.  
>> For discussion, the language could be something like, "Full CRL URLs MUST be 
>> provided in the CCADB before the CA signs certificates, or if it is already 
>> signing certificates, then within 7 days of disclosing the CA certificate in 
>> the CCADB." 
>> 
>> Thoughts?
>> 
>> Ben
>> 
>> 
>> 
>> On Tue, Aug 23, 2022 at 12:33 PM Christophe Bonjean 
>> <christophe.bonj...@globalsign.com 
>> <mailto:christophe.bonj...@globalsign.com>> wrote:
>> Hi Ben,
>>  
>> There’s a few CA and CRL lifecycle events linked to this change:
>> T= 0 : CA creation
>> T= 0 + a: CRL URL assignment (not yet publishing CRLs)
>> T = max 7 days: CA disclosure in CCADB (section 5.3.2)
>> T = 7 days + b: CRL disclosure in CCADB (section 4.1)
>> T = 7 days + c: First CRL published
>> T = d: First certificate issued from CA (with CRL in certificate profile)
>>  
>> The proposed change to section 4.1 means that CRLs need to be published as 
>> soon as they are being disclosed in CCADB. 
>>  
>> In some cases, CAs are generated a while before they are used, for example 
>> TLS CAs that we rotate on a quarterly basis. In that case, CRLs will only be 
>> published close to the when the CA becomes operational.
>>  
>> It seems the timeline to populate the CRL information in CCADB is currently 
>> flexible and supports this approach (i.e. populating and publishing the CRL 
>> a while after the CA is disclosed). 
>>  
>> Is this the correct understanding? If there’s a different interpretation or 
>> intention to restrict this timeline in the future, we would like to further 
>> discuss.
>>  
>> Thanks
>>  
>> Christophe
>>  
>> 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: Thursday, 11 August 2022 17:03
>> To: Corey Bonnell <corey.bonn...@digicert.com 
>> <mailto:corey.bonn...@digicert.com>>
>> Cc: Aaron Gable <aa...@letsencrypt.org <mailto:aa...@letsencrypt.org>>; 
>> dev-secur...@mozilla.org <mailto:dev-secur...@mozilla.org> 
>> <dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org>>
>> Subject: Re: CRL Issuance Frequency for non-published CRLs
>>  
>> All,
>>  
>> Mozilla's position is that adding CRL URLs to the CCADB (as required 
>> effective Oct. 1, 2022, by MRSP section 4.1 
>> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#41-additional-requirements>)
>>  will be considered "publishing" them because we will be relying on that 
>> information in the CCADB to operate CRLite. I have added Issue #251 
>> <https://github.com/mozilla/pkipolicy/issues/251> to GitHub to address this 
>> issue more precisely in the next version of the Mozilla Root Store Policy. 
>> For this, we will use the timeframes from section 4.9.7 of the Baseline 
>> Requirements, "the CA SHALL update and reissue CRLs at least once every 
>> seven days ...." (In the future, we might want to see that time frame 
>> shortened.)  
>>  
>> Thanks,
>>  
>> Ben Wilson
>> Mozilla Root Store Program
>>  
>>  
>> On Fri, Aug 5, 2022 at 1:08 PM 'Corey Bonnell' via 
>> dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org> 
>> <dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org>> 
>> wrote:
>> Hi Aaron,
>>  
>> > As long as we do not publish the CRLs, they are not required to be updated 
>> > on specific timetables.
>>  
>> My understanding is that absent the inclusion of a URI in a CRLDP extension 
>> of a Certificate that is subject to the BRs or some other Root Program 
>> requirement, there is no obligation by the CA to publish and update 
>> CRL-based revocation information on any specific cadence.
>>  
>> Given this, I believe that it’s compliant to not publish CRLs that are 
>> signed by the CA.
>>  
>> Thanks,
>> Corey
>>  
>> From: 'Aaron Gable' via dev-security-policy@mozilla.org 
>> <mailto:dev-security-policy@mozilla.org> <dev-security-policy@mozilla.org 
>> <mailto:dev-security-policy@mozilla.org>> 
>> Sent: Thursday, August 4, 2022 4:10 PM
>> To: dev-secur...@mozilla.org <mailto:dev-secur...@mozilla.org> 
>> <dev-security-policy@mozilla.org <mailto:dev-security-policy@mozilla.org>>
>> Subject: CRL Issuance Frequency for non-published CRLs
>>  
>> Hi MDSP,
>>  
>> Section 4.9.7 of the Baseline Requirements says (emphasis added):
>>  
>> > If the CA publishes a CRL, then the CA SHALL update and reissue CRLs at 
>> > least once every seven days, and the value of the nextUpdate field MUST 
>> > NOT be more than ten days beyond the value of the thisUpdate field.
>>  
>> Let's Encrypt is currently in the final stages of standing up infrastructure 
>> to issue and publish CRLs, in compliance with the upcoming Apple and Mozilla 
>> root program requirements that go into effect on October 1st.
>>  
>> As with many systems, we would like to test this as thoroughly as possible 
>> prior to making it fully available. Of course we're already running it in 
>> our non-production environment with an untrusted hierarchy of issuers. But 
>> there's a risk that, if we were to run the new infrastructure in our 
>> production environment and discover some sort of fault, we would not be able 
>> to turn it off again due to the reissuance and update requirements.
>>  
>> It is our interpretation of the above-quoted text from Section 4.9.7 that 
>> this risk does not actually exist. As long as we do not publish the CRLs, 
>> they are not required to be updated on specific timetables.
>>  
>> Does anyone disagree with this interpretation? Are there other requirements 
>> that I'm missing that would prevent us from turning the new infrastructure 
>> off?
>>  
>> Thanks,
>> Aaron
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Attachment: smime.p7s
Description: S/MIME cryptographic signature

  • CRL Issuance Freq... 'Aaron Gable' via dev-security-policy@mozilla.org
    • RE: CRL Issu... 'Corey Bonnell' via dev-security-policy@mozilla.org
      • Re: CRL ... Ben Wilson
        • Re: ... 'Aaron Gable' via dev-security-policy@mozilla.org
        • RE: ... 'Christophe Bonjean' via dev-security-policy@mozilla.org
          • ... Ben Wilson
            • ... 'Clint Wilson' via dev-security-policy@mozilla.org
            • ... 'Christophe Bonjean' via dev-security-policy@mozilla.org
    • Re: CRL Issu... 'Rob Stradling' via dev-security-policy@mozilla.org
      • Re: CRL ... 'Clint Wilson' via dev-security-policy@mozilla.org
    • Re: CRL Issu... 'Rob Stradling' via dev-security-policy@mozilla.org
    • Re: CRL Issu... 'Rob Stradling' via dev-security-policy@mozilla.org

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