All,

This email is to open discussion here on the m-d-s-p list regarding the
resolution of GitHub Issue #275
<https://github.com/mozilla/pkipolicy/issues/275> (Emphasize period-of-time
key lifecycle management in MRSP § 3.1.3).

Part of the issue, as I see it, is to strengthen key protection
requirements for *all* keys that are intended to serve as CA keys,
including pre-generated CA keys that a CA operator might create. Sometimes
cryptographic key pairs are generated but not yet used to issue a CA
certificate (because, for example, the standards sometimes require auditor
presence at "key generation" but not at certificate creation). An auditor's
key generation report is likely useless if CA keys are subsequently
unprotected.
So, at least one goal is to create clarity with requirements that address
the lifecycle management of these "parked" CA keys.

Here are some proposed edits to the Mozilla Root Store Policy (MRSP)

Proposed edits to the MRSP
<https://github.com/mozilla/pkipolicy/compare/28a519327a21bebafc1cc3721d4376ba85bf3f98...e1a7f4e77f4988600b4d5caeb3cba172d7818a26>
(lines 273 and 746)

Mainly this adds to MRSP § 3.1.3, "CA private keys that have been generated
but not yet associated with a CA certificate ("parked keys") MUST be
identified and included in auditor-provided annual key lifecycle management
reports (or a corresponding section of the CA operator's annual audit
reports). These reports must account for the controls and measures applied
to ensure the integrity, confidentiality, and protection of these keys
throughout their lifecycle, consistent with the audit criteria cited above".

The CA/B Forum's TLS Baseline Requirements has a similar issue (see e.g.
https://github.com/cabforum/servercert/issues/417).

Proposed edits to the TLS BRs
<https://github.com/cabforum/servercert/compare/096810820d605d1a2c90a9b10e4ef36ed65bd6cc...d07ff6e148b9003938c47b23878d0065ea9d65d5>
(CABF Server-Cert GitHub Repository)

Please provide any comments or suggestions you might have to resolve, or
otherwise improve this proposed resolution of, Issue #275.

Thanks,

Ben

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