> Delayed revocation is a measure of last resort and MUST not be used routinely.

Hi Ben.  One nit: That "not" should be capitalized.
________________________________
From: 'Ben Wilson' via [email protected] 
<[email protected]>
Sent: 13 January 2025 17:00
To: [email protected] <[email protected]>
Subject: Re: MRSP 3.0: Issue #276: Delayed Revocation

All, It has been recommended that Mozilla replace its wiki page on delayed 
revocation incident reporting. Here is a draft for your review and comment. Ben 
URL: https: //wiki. mozilla. org/CA/Responding_To_An_Incident#Revocation Goals: 
Mozilla’s

All,

It has been recommended that Mozilla replace its wiki page on delayed 
revocation incident reporting.  Here is a draft for your review and comment.

Ben


URL:  
https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation<https://urldefense.com/v3/__https://wiki.mozilla.org/CA/Responding_To_An_Incident*Revocation__;Iw!!J5K_pWsD!w0cRRnDtbjC3g_ZEH3BY2O71Hym6p7KAodvveMc4cdDTkDwbb5rmvRRhS3-k8T6KigRjWDS5855ZjhHPST8fRcbOYw$>


Goals:  Mozilla’s goals are: to ensure that revocation occurs as swiftly as 
possible while maintaining the overall security and stability of the web; to 
reduce delayed revocation incidents to the greatest extent possible; to improve 
delayed revocation incident reports; and to gather better information on those 
cases where delayed revocation occurs.


Date to Go Live:  January 17, 2025


Revocation

Mozilla’s Expectations on Revocation

CA operators MUST revoke misissued or otherwise problematic TLS server 
certificates within 24 hours or 5 days, depending on the circumstances set 
forth in section 
4.9.1<https://urldefense.com/v3/__https://cabforum.org/working-groups/server/baseline-requirements/requirements/*491-circumstances-for-revocation__;Iw!!J5K_pWsD!w0cRRnDtbjC3g_ZEH3BY2O71Hym6p7KAodvveMc4cdDTkDwbb5rmvRRhS3-k8T6KigRjWDS5855ZjhHPST-gAzsjGw$>
 of the CA/Browser Forum’s TLS Baseline Requirements (TLS BRs).  Mozilla does 
not grant exceptions to the revocation requirements of the TLS BRs.

To ensure compliance with the TLS BRs, Mozilla requires that CA operators:

  *   engage in proactive communication and advise subscribers well in advance 
about the revocation timelines and explicitly warn them against using 
publicly-trusted TLS server certificates on systems that cannot tolerate timely 
revocation;

  *   include appropriate language in customer agreements requiring 
subscribers’ timely cooperation in meeting revocation timelines and 
acknowledging the CA’s obligations to adhere to applicable policies and 
standards;

  *   prepare and maintain credible plans to address mass revocation events, 
including detailed procedures for handling mass revocations effectively, 
including rapid communication with affected parties and conducting annual plan 
testing; and

  *   engage a third party assessor to evaluate whether the CA Operator has:

     *   credible plans to handle mass revocation events;

     *   tested the operational effectiveness of the plans, including the 
accuracy and adequacy of documentation of plan testing, including timelines, 
results, and remediation steps; and

     *   incorporated feedback from such exercises to improve future readiness.

Incident Reporting

The CCADB incident reporting 
process<https://urldefense.com/v3/__https://www.ccadb.org/cas/incident-report__;!!J5K_pWsD!w0cRRnDtbjC3g_ZEH3BY2O71Hym6p7KAodvveMc4cdDTkDwbb5rmvRRhS3-k8T6KigRjWDS5855ZjhHPST89bo_N9g$>
 ensures the Web PKI community is informed and that issues are tracked and 
resolved effectively. Clear and timely communication fosters trust and 
accountability, mitigating risks to the ecosystem.

If a CA operator determines that it might delay revocation of certificates 
beyond the time period required by the TLS BRs, it MUST file a preliminary 
incident report with a Summary section immediately in Bugzilla, even if the 
delay has not yet occurred.

Such delayed revocation incident reports SHOULD be updated at least every 3 
days and MUST be updated no less frequently than every 7 days to describe a 
summary of:

  *   the number of certificates that have been revoked;

  *   the number of certificates that have not yet been revoked;

  *   the number of certificates planned for revocation that have expired; and

  *   an estimate for when all remaining revocations will be completed.

Consistent with CCADB incident reporting requirements, in the “Analysis” 
section, the CA operator SHALL explain in the Analysis section of the incident 
report those factors and rationales behind the decision to delay revocation 
(including detailed and substantiated explanations of how extensive harm would 
result to third parties–such as essential public services or widely relied-upon 
systems–and why the situation is exceptionally rare and unavoidable).

Also, the Timeline section should include the time(s) at which the CA Operator 
actually completed revocation of affected certificates, and the Action Items 
list MUST include steps reasonably calculated to prevent or reduce future 
revocation delays.

Consequences of Delayed Revocations

Failing to meet the standards of timely revocation erodes trust in the Web PKI 
and poses risks to global internet security.  Delayed revocation is a measure 
of last resort and MUST not be used routinely.  Repeated incidents of delayed 
revocation without sufficient justification will result in heightened scrutiny 
and sanctions, including removal of the CA from the Mozilla Root Store. CA 
operators must also adhere to the policies and revocation requirements of other 
Root Store Programs that include their CA certificates.  Additionally, all 
delayed revocation incidents MUST be listed as findings in the CA operator’s 
next TLS BR audit statement.



On Saturday, January 11, 2025 at 8:04:43 PM UTC-7 Matt Palmer wrote:
On Fri, Jan 10, 2025 at 06:21:02PM -0800, Suchan Seo wrote:
> Wouldn't fixed 30 certificates per CA cause smaller CA just spam load
> genenrate test certificates on production envirement to delude chance to it
> actually hit acutal client?

It is certainly a possibility. However, that sort of thing leaves
extensive evidence (which, I will note, a CA-driven "random" choice
protocol does not), and if such evidence was found and brought to light
publicly, I expect it would not reflect well on the CA involved.

Also, in the protocol I proposed, as Mozilla has full discretion over
the the criteria by which certificates are chosen for a revocation test,
it does not have to select those certificates entirely at random. It
could identify certificates issued for the purposes you describe, and
just not include such certificates in the list of those to be revoked.

- Matt


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