I don't understand why these proposals exist. We have a process for delayed
revocation already, it's called Filing An Incident.

On Sat, Sep 28, 2024 at 8:28 AM Mike Shaver <[email protected]> wrote:

> Hi Ben,
>
> First, thanks for this proposal. It is excellent leadership on the part of
> Mozilla and yourself to address the underlying cause of chronic delayed
> revocation: incentives that are mismatched with the goals and needs of the
> Web PKI. I think it represents tremendous progress towards a healthier and
> more secure Web PKI, which is to say one for which relying parties can be
> more confident that certificates they encounter are properly issued and
> trustworthy. Backtesting this against the last year’s incidents paint the
> future you describe in a much more pleasant colour than the recent past we
> endured as a community.
>
> Some more specific comments:
>
> On Thu, Sep 19, 2024 at 5:53 PM 'Ben Wilson' via
> [email protected] <[email protected]> wrote:
>
>> We’re skeptical about proposals to pre-identify domains that will require
>> delayed revocation.
>>
> Agree.
>
>> 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.
>>
> One notable issue we’ve seen in the past is differing understanding of
> what constitutes “substantial harm” or “critical infrastructure”. I
> recognize that it will require a fair bit of deliberation and debate to
> settle on one even for the scope of Mozilla’s root program, let alone the
> broader CA/BF community, but I think it is important to nail that down more
> crisply and to avoid skew between CAs.
>
>
>>    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;
>>
>>
> I think we need a template or similar to show what the necessary
> information is, and to reinforce the criteria for “critical infrastructure”
> or similar. I volunteer to draft one in October, drawing hopefully on the
> wisdom of this community, if that would be helpful.
>
>
>>    1. 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);
>>
>>
> We should expect that there will be push-back on this via security or
> other such angles, but I agree that it’s important.
>
> “Not possible” isn’t really appropriate here, IMO, since it’s very rarely
> physically prohibited given sufficient investment and assumption of risk.
> Goes back to the “substantial harm” definition, sort of.
>
>
>>    1. 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;
>>
>>
> Extremely good.
>
>
>>    1.
>>
>>       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);
>>
>>
> What might the consequence be if this were found to not be honoured? One
> challenge of the current policy around delayed revocation is that there
> isn’t a clear “or else”.
>
>
>>    1. That each granted request be published for the community (and
>>       Mozilla) to scrutinize (allowing CAs to redact PII prior to 
>> publication);
>>       and
>>
>>
> Should this be limited to granted requests, or others that the CA might
> themselves have declined? I think the additional visibility would help CAs
> and others refine their communication with subscribers in order to improve
> alignment on the criteria. It might also disincentivize subscribers from
> trying “just in case it works” and creating additional work for CAs and
> others evaluating these requests in good faith.
>
>
>>    1.
>>
>>       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).
>>
>>
> I like the idea of the centralized list, but I’m concerned that it puts
> CCADB infrastructure in the critical path of certificate issuance. That’s a
> big operational responsibility and a type of centralized dependency that
> AFAIK doesn’t currently exist in the ecosystem. Could we find a way to
> piggyback on CT or similar infrastructure, which is already maintained to
> the standards required?
>
>
>>    1. We would also look to align these policies across the root
>>       programs in order to provide clarity for the entire community.
>>
>>
> I agree that cross-program alignment would be valuable, but I would hope
> that it wouldn’t be a prerequisite for Mozilla adopting a policy. Some root
> programs are more engaged than others in these matters, and letting them
> delay the implementation of an improvement like this one would be
> unfortunate.
>
> Mike
>
> Apologies for this Gmail nonsense:
>
>
>>    1.
>>
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