All,

This email opens up discussion of our proposed resolution of GitHub Issue
#258 <https://github.com/mozilla/pkipolicy/issues/258> (SMIME Baseline
Requirements).

We plan to add requirements to version 2.9 of the Mozilla Root Store Policy
<https://www.mozilla.org/projects/security/certs/policy/> regarding the
CA/Browser Forum’s S/MIME Baseline Requirements.

We propose to update Mozilla’s Root Store Policy to require annual S/MIME
BR audits as follows.

   -

   Section 2.2, second bullet point modified to directly reference that
   email verification must be in accordance with section 3.2.2 of the S/MIME
   BRs
   -

   Section 2.3,
   -

      First paragraph – add the following sentence (as a second sentence):

Certificates issued on or after September 1, 2023, that are capable of
being used to digitally sign or encrypt email messages, and CA operations
relating to the issuance of such certificates, MUST conform to the latest
version of the CA/Browser Forum Baseline Requirements for the Issuance and
Management of Publicly-Trusted S/MIME Certificates.

   -

   Change the remaining references of “Baseline Requirements” in this
   section to “S/MIME and TLS Baseline Requirements”. To indicate that the
   statements apply to both.


   -

   Section 3.1.2
   -

      Add ETSI TS 119 411-6 as audit criteria
      -

      Add WebTrust for CAs - S/MIME as audit criteria
      -

   Sections 3.2, 3.3, 5.2, 7.1
   -

      Change “Baseline Requirements” to “S/MIME and TLS Baseline
      Requirements”. To indicate that the statements apply to both.
      -

   Section 5.1 add a statement:  “The following curves are not prohibited,
   but are not currently supported:  P-521, Curve25519, and Curve448.”
   -

      And add a sentence:  “EdDSA keys MAY be included in certificates that
      chain to a root certificate in our root program if the
certificate contains
      ‘id-kp-emailProtection` in the EKU extension. Otherwise, EdDSA keys MUST
      NOT be included.”
      -

   Section 5.3.1
   -

      Move the following sentence from the end of the current second
      paragraph up to its own stand-alone paragraph.
      -

         "The conformance requirements defined in section 2.3 of this
         policy also apply to technically constrained intermediate
certificates."
         -

      Revise last paragraph with proposed new text:
      -

         “If the intermediate CA certificate includes the
         id-kp-emailProtection extended key usage, then to be
considered technically
         constrained, it MUST comply with section 7.1.5 of the S/MIME
         Baseline Requirements <https://cabforum.org/smime-br/> and include
         the Name Constraints X.509v3 extension with constraints on
rfc822Name, with
         at least one name in permittedSubtrees, each such name having
its ownership
         validated according to section 3.2.2 of the S/MIME Baseline
         Requirements <https://cabforum.org/smime-br/>.”
         -

   Change remaining existing occurrences of “Baseline Requirements” to “TLS
   Baseline Requirements”.

We look forward to your constructive feedback on these proposed changes to
the MRSP.

We will start a separate discussion about dates/timelines and when
compliance audits will be due for these new requirements.

Regards,

Ben and Kathleen

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  • MRSP 2.9: S/MIME ... Ben Wilson

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