On Thu, Sep 19, 2024 at 03:53:16PM -0600, 'Ben Wilson' via 
[email protected] wrote:
>    1.
>
>    Clarification of existing requirements
>    We would be more explicit about what would be required for delayed
>    revocation. Some ideas include:
>    1.
>
>       Explicitly clarifying that CAs must revoke certificates by default,
>       that any delayed revocation must be the result of an explicit request by
>       the subscriber, containing the necessary information, and meeting the
>       requirements under such interim policy;

If there are any CAs that currently think that they *shouldn't* revoke
certificates by default, I would be very deeply concerned.

>       2.
>
>       That subscriber requests contain a clear claim or explanation about
>       the critical nature of the system and why timely revocation is
> not possible
>       (more detailed requirements to be discussed);
>       3.
>
>       That the requests are signed by a company officer, or similar legal
>       representative, stating that the information in the request is
> accurate to
>       the best of their knowledge;
>       4.
>
>       That the information contained in the subscriber’s request be
>       accurate to the CA’s understanding (e.g. not materially contradicted by
>       other facts known to the CA);
>       5.
>
>       That each granted request be published for the community (and
>       Mozilla) to scrutinize (allowing CAs to redact PII prior to 
> publication);
>       and

Requiring publication of the detailed reasons for delayed revocation as
part of a delayed revocation report would be a great benefit to the
WebPKI, I believe.

>       6.
>
>       That CAs be required to produce summary statistics in their reports
>       (alongside the individual granted requests) detailing how many requests
>       were received, how many were well-formed, how many were granted, etc.

This, too, would be valuable information to improve the visibility and
resilience of the WebPKI.

>    Consequences of Delayed Revocation
>    We believe that if a domain hosts critical infrastructure that cannot
>    tolerate timely revocation, then it is deeply damaging to the web PKI. In
>    order to help these domains transition to effective certificate management
>    practices and automated tooling, we propose that domains that are granted
>    delayed revocation must then be limited to shorter-lifetime certificates as
>    a consequence of such decision. This also ensures that future revocations
>    impacting such domains have much less impact.

I believe this would be an admirable improvement, because as you say, a
shorter lifetime for such certificates reduces the period of time in
which a known-flawed certificate could be misused, if revocation were
significantly delayed for some reason.

Taking this thought to its logical conclusion, if a certificate is so
important that revocation is too dangerous to execute within the
strictures of the WebPKI, it should be moved to a seven-day lifetime,
which as I understand it means that the CA is no longer required to
revoke.

>    Concretely, the domains accepted for delayed revocation by a CA are
>    already public. If this proposal were to be adopted, root programs would
>    manage a shared list of such domains (e.g. via the CCADB) and require CAs
>    to limit the lifetimes of certificates issued to these domains (e.g. to 90
>    days).

By "domain", are you referring to FQDN (ie sAN values) or the associated
eTLD+1?  I would expect it to be FQDN, based on my understanding of the
intent, but it's worth clarifying, IMO, to ensure everyone's on the same
page.

- Matt

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