I have no concerns with the proposal as-written, and would like to thank 
Mozilla for taking feedback on the prior proposal.

- Wayne

On Thursday, September 19, 2024 at 10:53:30 PM UTC+1 Ben Wilson wrote:

> Hi folks, 
>
> We have discussed delayed revocation a bit internally and wanted to come 
> back to the community with some thoughts. 
>
> We agree that expanding beyond the existing revocation timelines (24 hours 
> / 5 days) is undesirable. While we think some exceptional delayed 
> revocations are necessary as a current practicality, we do want to 
> eventually sunset this policy. To that end, we’d like to refine our 
> existing policy so that it is more effective and equitable during the 
> interim. 
>
> We’re skeptical about proposals to pre-identify domains that will require 
> delayed revocation. We expect that many sites might ask for such 
> exceptions, and an extensive amount of deliberation would be required in 
> order to process these requests. Worse, in practice, doubtless some sites 
> impacted in a revocation event would not have followed the procedure, and 
> CAs would still be left with a last-minute decision about whether a 
> revocation will inflict substantial harm. 
>
> Instead, we would like to seek the community's feedback on the following 
> two proposals: 
>
>    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;
>       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
>       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. 
>       
>       2. 
>    
>    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. 
>    
>    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). 
>    
> We stress that both of these proposals are presented for early feedback, 
> and we look forward to the community’s thoughts on whether they are likely 
> to be suitable and effective, and how they might be improved. We would also 
> look to align these policies across the root programs in order to provide 
> clarity for the entire community. 
>
> Thanks and best wishes, 
>
> Ben
>

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