Which CAs are even publicly traded at this point – Google, Amazon, Entrust?  
Plus, do government CAs qualify as having independently and publicly available 
audited financial statements? What about services like Let’s Encrypt? They 
publish a report on their finances but I think that report is written by Let’s 
Encrypt, not independent auditors?  I’d venture most of the CAs in the root 
program don’t meet both the independent and publicly available statements.  

 

I don’t like this requirement because it means only small subsidiaries of very 
large organizations can be a CA. 

 

 

From: dev-security-policy@mozilla.org <dev-security-policy@mozilla.org> On 
Behalf Of Matthew Hardeman
Sent: Thursday, February 9, 2023 11:11 AM
To: Kathleen Wilson <kwil...@mozilla.com>
Cc: dev-security-policy@mozilla.org
Subject: Re: DRAFT: Root Inclusion Considerations

 

As a rule, you tend to have to be a pretty significant business operation to 
have accounts / financial statements that are "independently audited or 
examined."

 

Even many small businesses have their financials and tax accounting reviewed 
and prepared by accounting professionals.  But that's different from a formal 
assertion of "independently audited or examined."

 

In the US, publicly traded corporations would be.  But many private entities 
would not.  It can add a significant time investment and significant 
expenditure to go that extra step and get an assertion from the accountant that 
the financials represented in the report do materially reflect the state of the 
business.

 

Without expressing a particular opinion on the matter, I believe that you 
should contemplate whether any risk mitigation value of imposing such burdens 
outweighs the costs to the CA / prospective CA.

 

On Thu, Feb 9, 2023 at 11:54 AM Kathleen Wilson <kwil...@mozilla.com 
<mailto:kwil...@mozilla.com> > wrote:

Would it be reasonable to add the following as a Concerning Behavior?

 

- The CA does not publish annual accounts or financial statements that have 
been independently audited or examined.

 

This has been suggested to me via email, but I am not versed in this area.

 

Thanks,

Kathleen

 

 

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