All,

I have reviewed many of the CA operator survey responses, and I am working
to present them in a structured and insightful way. I am also preparing an
FAQ document that will provide further implementation and compliance
guidance for CA operators to address many of the questions and concerns
raised in their responses to the survey questions.

To facilitate the display of recent changes to the draft of MRSP 3.0, I
have created an additional branch in GitHub—*Updates-from-Survey-Responses
<https://github.com/mozilla/pkipolicy/tree/Updates-from-Survey-Responses>*—which
reflects proposed revisions based on the feedback received. And, for a
direct comparison between the language in the current MRSP 3.0 branch and
this new GitHub branch, see:  *Comparison of Branches
<https://github.com/mozilla/pkipolicy/compare/695d6c318875a912a4a5ce3fa0d0f6aa1ca5f0d6%E2%80%A6a1a8afe442844db6b9048b4c6bc750ca49c43216>*
.

One other key step that I’m working on is to prepare MRSP 3.0 for
publication on the Mozilla website, pending legal review. We are on track
for this, and I want to reaffirm our commitment to the March 1, 2025,
effective date.

To ensure everyone is aligned with upcoming compliance milestones, here’s a
brief overview of key dates (some of which are included in the new GitHub
branch):

   - *January 1, 2025*: Newly included root CA certificates cannot be
   dual-purpose (i.e. enabled for both website authentication and email
   protection). Also, any new root CA certificates with the websites trust bit
   enabled must demonstrate automated issuance capabilities.
   - *March 1, 2025*: This is the official compliance date when new
   requirements take effect, unless otherwise specified.
   - *Annual audit periods beginning after March 1, 2025*: CA operators
   must begin identifying “parked CA keys” in their annual audit reports.
   - *Annual audit periods beginning after June 1, 2025*: A CA operator
   capable of issuing trusted TLS certificates must obtain a third party
   assessment of the maintenance and testing of its mass revocation plan.
   - *September 1, 2025*: All CA operators must have a mass revocation plan
   in place and begin the process to have it tested and evaluated (in
   accordance with the previous bullet).
   - *April 15, 2026*: Any CA operating a dual-purpose root (with both
   websites and email trust bits enabled) must submit a transition plan to
   Mozilla.
   - *December 31, 2028*: The final transition deadline, by which no root
   CA certificate will have both trust bits enabled.

If you have any questions or need further clarification, please don't
hesitate to reach out.

Thanks,

Ben

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