On Fri, Feb 7, 2025 at 8:41 AM Mike Shaver <[email protected]> wrote
https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/pq2VZAg1QUQ/m/96XQcYacAgAJ:
 


https://bugzilla.mozilla.org/show_bug.cgi?id=1942879 - Issue identified and 
the delay was unintentional  -> Note that in this case the issue was 
"malware filtering blocked CPR", which was sufficiently distinct from "spam 
filter blocked CPR" that multiple CAs did not extrapolate from the latter 
to the former when monitoring previous incidents. This makes me feel that 
perhaps more attention could be paid by the *root programs to explaining 
how they expect CAs to address classes of issue*, rather than just the most 
narrowly-interpreted case specifically implicated in an incident. Closing 
the bug ahead of that clarity coming from root programs or, failing that, 
peer CAs or other community members, seems like a missed opportunity to 
avoid future incidents like "we block things that have a non-ASCII sender 
name" or whatever the next fine speciation would be.


For guidance on defining classes of issues to provide guidance on, we have 
at least somewhere to start:

1- *Whiteboard Incident Classifications*  (
https://wiki.mozilla.org/CA/Bug_Triage#Whiteboard_Tags)
2- *Lessons Learned* (https://wiki.mozilla.org/CA/Lessons_Learned)
3- *Statistical summaries of incidents* (Mozilla root program reports to 
the CABF).  E.g.:

   - 
   
https://cabforum.org/uploads/5-2023-February-Mozilla-Update-CABF-Ottawa-F2F.pdf
   - 
   
https://cabforum.org/2024/05/28/minutes-of-the-f2f-62-meeting-in-bergamo-italy-may-28-29-2024/3-May-2024-Mozilla-News.pdf
   - 
   
https://cabforum.org/2024/02/26/minutes-of-the-f2f-61-meeting-in-new-delhi-india-february-26-27-2024/2-February-2024-Mozilla%20Browser%20News.pdf

>From here, we could try and create high-level guidance and clarify 
expectations for each general class of issue (guidance on how CAs should 
interpret and implement root program requirements, how CAs should handle 
revocation, disclosure, and incident reporting). Here is another 
classification list with 7 high-level categories:

1. Certificate Issuance Issues

   - Misissuance of Certificates (e.g., improper domain validation, 
   incorrect key usage, subject DN errors)
   - Inadequate Pre-Issuance Linting (failure to detect BR violations 
   before issuance)
   - Certificate Profiles and Extensions (incorrect EKUs, lack of 
   compliance with current standards)

2. Validation and Identity Verification Failures

   - Domain Validation (DV) Weaknesses (improper DNS, HTTP, or email 
   validation)
   - Organization Validation (OV) and Extended Validation (EV) Failures 
   - S/MIME Validation Failures (misinterpretation of identity proofing 
   requirements)
   - Wildcard and Multi-Domain Certificate Validation 

3. Revocation Response Failures

   - Failure to Revoke in a Timely Manner (delayed response to misissuance 
   or compromise)
   - Inadequate Revocation Reasoning (inconsistent or improper use of 
   revocation reason codes)
   - Delayed Revocation Justifications (unsubstantiated or improperly 
   handled delayed revocation cases)
   - Revocation Checking Failures (OCSP, CRL unavailability or poor 
   performance)
   - Improper Handling of Key Compromise (delayed responses)

4. Incident Reporting and Root Program Communication Issues

   - Delayed or Incomplete Incident Reports (not reporting security or 
   compliance incidents in a timely manner)
   - Insufficient Root Program Notification (failure to disclose new 
   intermediates or key lifecycle events)
   - Disclosure Failures in CCADB (not updating CCADB with required 
   information in a timely manner)
   - Failure to Address Prior Incidents (repeated issues due to inadequate 
   corrective actions)
   - Misclassification of Incidents (underreporting or misreporting 
   compliance issues)

5. Policy and Compliance Failures

   - Non-Conforming Certificate Policies and CPS Documents (failure to 
   align with BRs or root program policies)
   - Inconsistent Policy Updates (failure to update CP/CPS to reflect new 
   requirements)
   - Failure to Implement New Root Program Policies (e.g., delays in 
   adopting MPIC, new S/MIME Baseline Requirements)

6. Subscriber-related Issues

   - Inadequate Subscriber Agreements (lack of proper subscriber 
   obligations)
   - Failure to Educate Subscribers on Proper Certificate Usage 
   - Failure to Support Automation for Subscribers (slow migration to ACME 
   or automated certificate renewal)

7. Ecosystem-Wide Issues Affecting Multiple CAs

   - Inconsistent Handling of Email Filtering Issues (spam/malware blocking 
   certificate problem reports)
   - Failure to Keep Up with Changes in Industry Standards (e.g., MPIC, 
   CAA, etc.)
   - Failure to Address Systemic Risks in CA Practices (repeated 
   industry-wide issues, lack of proactive mitigation)

I am open to suggestions on how to move forward in response to Mike's 
comment.

Thanks,

Ben

. 


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