On 13/4/2025 4:18 μ.μ., Arabella Barks wrote:
Dear Ben,

Does firefox respect certificate's AIA Extension(Authority Information Access) like Ryan and chrome did? It is important for cloudflare customers to reduce their lose those who installed SSL.com's non-cross-signed certificates chaining to AAA Certificate Services.

Dear Ara,

I don't think there is any trust issue, primarily because of the alternative paths. Older devices that do not update their Root Stores will continue to trust the old Root Certificate while newer devices will trust the new Root Certificate.

AIA chasing is a mechanism which is more targeted to help with missing intermediate CA Certificates from TLS server (mis-)configurations in the CA Certificate chains.


Thanks,
Dimitris.

Thank you.
Ara
On Friday, April 11, 2025 at 11:58:13 PM UTC+8 Ben Wilson wrote:

    Hi Martijn,
    Just one clarification regarding the current state of the
    transition plan: it currently specifies distrustAfter dates for
    S/MIME roots.
    See https://wiki.mozilla.org/CA/Root_CA_Lifecycles
    We're open to input on whether any similar changes should be
    considered for TLS CAs.
    Also, please keep in mind that, going forward, root store programs
    might aim to align on a common removal framework to give CA
    operators better predictability around when their root
    certificates will no longer be trusted. However, we're not there yet.
    Thanks,
    Ben

    On Fri, Apr 11, 2025 at 9:36 AM 'Martijn Katerbarg' via
    [email protected] <[email protected]> wrote:

        Hi Dimitris,

        I’m forking this to a new thread to separate from the delayed
        trust bit removal thread.

        >Can you please share more details about the risks you see between
        the following options, for a Root CA with a hierarchy that no
        longer issues new end-entity certificates (OCSP responder
        certificates excluded) and all of its subscriber certificates
        have either been revoked or expired?

        I want to clarify here that just because the trust bits are
        being removed from Mozilla/NSS and Chrome it doesn’t mean
        there won’t be some unexpired leaf certificates, or even new
        certificate issuance from the hierarchy for a small number of
        subscriber edge cases.

        For the sake of this discussion, I’ll leave in the middle
        whether these edge cases are good or bad. We certainly see
        both. I also believe the WebPKI is currently in a more active
        transformational state, one where proper customer education
        about using the right PKI at the right location is more
        important than ever.

        1. Utilizing distrust notAfter/notBefore modern browser methods

        2. Removal of "trust bits"

        3. Removal of the Root CA entirely, especially if there are no
        "trust bits" enabled.

        I want to say here that we believe all three mechanisms should
        be utilized, in the correct order (frankly, the one you
        specified).

        At this moment, number 2 and 3 are utilized by Mozilla for the
        scheduled deprecations due to CA key lifetimes. The main
        reason for this is the different removal dates for SMIME and
        TLS. As an example for a multipurpose root:

        - 2025-04-15: TLS trust bit removal

        - 2028-04-15: S/MIME trust bit removal / complete Root CA removal.

        When looking at single purpose hierarchies, the direct Root CA
        removal could be the first step.

        We would like to advocate adding the first option at the
        beginning of the process, changing the example to:

        - 2024-04-15: DistrustAfter set for TLS and S/MIME

        - 2025-04-15: TLS trust bit removal

        - 2028-05-15: Complete Root CA removal

        We believe this approach would help significantly to make root
        deprecations smoother for CAs and Subscribers alike.

        What this change would essentially force is setting a single
        date for both TLS and S/MIME, after which any newly issued
        certificate won’t be trusted by Mozilla.

        The issue we see currently is that certificates issued at the
        same time have different trust removal dates. As an example,
        with our AAA Certificate Services Root CA:

        - A TLS certificate issued on 2025-01-15 for 200 days, after 3
        months will stop being trusted.

        - A TLS certificate issued on 2025-02-15 for 30 days, would be
        trusted for its entire lifetime.

        - An S/MIME certificate issued on 2026-04-15 for 3 years,
        would have its trust removed after 2 years.

        - An S/MIME certificate issued on 2027-04-15 for 1 year, would
        be trusted for its entire lifetime.

        We believe (and have noticed in practice) that this easily
        leads to confusion, whereas having a single “DistrustAfter”
        date based on the notBefore date for all certificate types
        allows for more clarity.

        Additionally, using “DistrustAfter” also has the benefit of
        showing a non-trusted state immediately after installation of
        a certificate, rather than (for the Subscriber and Relying
        Parties perspective) at a random moment.

        While a CA could obviously choose to halt issuance early on a
        hierarchy to ensure all leaf certificates expire before the
        root removal date, that would no longer allow for the sorts of
        subscriber edge cases that I touched on above.

        Regards,

        Martijn

        *From: *'Dimitris Zacharopoulos' via [email protected]
        <[email protected]>
        *Date: *Thursday, 10 April 2025 at 07:15
        *To: *[email protected] <[email protected]>
        *Subject: *Re: Postponement of Removal of Websites Trust Bit
        for ePKI Root CA

        Martijn,

        Can you please share more details about the risks you see
        between the following options, for a Root CA with a hierarchy
        that no longer issues new end-entity certificates (OCSP
        responder certificates excluded) and all of its subscriber
        certificates have either been revoked or expired?

         1. Utilizing distrust notAfter/notBefore modern browser methods
         2. Removal of "trust bits"
         3. Removal of the Root CA entirely, especially if there are
            no "trust bits" enabled.

        I'm very interested to hear the ecosystem risks for each of
        these choices. It feels that the order is correct in terms of
        risks but I'm more interested to hear what you and others feel
        about the 3rd option.

        Best regards,

        Dimitris.

        On 9/4/2025 11:10 μ.μ., 'Martijn Katerbarg' via
        [email protected] wrote:

            All,

            > If Mozilla directly removes the "AAA Certificates
            Servies" and others, more than 12,435,053 websites issued
            by "Cloudflare TLS Issuing ECC CA 1" will be affected, It
            has bad impact on the business of CloudFlare's customers.
            > The above is what I have found out through about few
            minutes of research, based on the sites count and I think
            it will have a gravity impact.
            > I request the community to conduct an assessment to
            reduce this impact.
            As already pointed out by Ryan, these certificates can all
            be validated through multiple chains.
            With the experience we’ve gained from preparing for this
            root certificate removal, we do want to add that we
            believe future scheduled root certificate deprecations
            would benefit from utilizing the mechanisms for distrust
            based on notBefore (Mozilla) and SCTNotAfter (Chrome),
            rather than a hard deadline for trust bit removal. This
            probably warrants its own discussion thread though,
            potentially on the CCADB Public list.
            > Please consider avoiding the DistrustAfter strategy. It
            causes problems for tools which use Google, Mozilla (and
            friends) curated lists of trusted CAs. The tools include
            utilities like cURL and Wget.
            We don’t agree with this. The DistrustAfter mechanism is
            one very suitable for a graceful removal of trust, be it
            for scheduled deprecations, or other forms of trust removal.
            The tools mentioned, or more broadly, Linux distributions
            that build their ca-certificates packages based on the
            data available in Mozilla/NSS, have hopefully chosen to do
            so for a reason: They believe the open source root store
            that Mozilla provides fits their needs and provides the
            transparency the open source community is usually looking
            for.
            If the Mozilla root store believes the DistrustAfter
            mechanism is viable and is a better option (which we agree
            with in general), then the parties relying on the root
            store need to adjust to follow that guidance, or re-assess
            their needs. They should at no point be holding back
            innovation and improvements of the Mozilla root store / NSS.

            We’d like to remind everyone of this Mozilla blog post
            
<https://blog.mozilla.org/security/2021/05/10/beware-of-applications-misusing-root-stores/>,
            which mentions this wiki page
            <https://wiki.mozilla.org/CA/Additional_Trust_Changes>
            that discusses additional factors (including
            DistrustAfter) that application developers need to be
            aware of if they are using Mozilla’s root store.

            Regards,

            Martijn Katerbarg
            Sectigo

            Op woensdag 9 april 2025 om 19:08:43 UTC+2 schreef Ryan
            Dickson:

                Hi Arabella,

                The example provided can validate to multiple
                <https://crt.sh/?graph=15005443728&opt=nometadata> anchors.


                For example, an alternate path to an SSL.com root is
                provided below.

                Anchor: SSL.com TLS ECC Root CA 2022
                
<https://crt.sh/?q=c32ffd9f46f936d16c3673990959434b9ad60aafbb9e7cf33654f144cc1ba143>

                 ---> SSL.com TLS Transit ECC CA R2
                
<https://crt.sh/?q=5d1bc399274e649e1c72697de91a54ad725088c5221cb61e17ee9c290bc42a92>

                 ---> Cloudflare TLS Issuing ECC CA 1
                
<https://crt.sh/?q=2964fd3210ea68faa2b4a849b36243d33f74429d1b43ce019e7b154eac7759ba>

                ---> www.relialabtest.com
                
<https://crt.sh/?q=133f15fc8303dccb6b319b65c6d9f2ff9ae1c0fea4abf2eaf70939d77240dc0a>

                Hope this helps!

                - Ryan

                On Wed, Apr 9, 2025 at 12:40 PM Arabella Barks
                <[email protected]> wrote:

                    Sorry, I forgot to post one case
                    https://www.relialabtest.com it is the hierarchy I
                    mentioned.

                    On Thursday, April 10, 2025 at 12:36:03 AM UTC+8
                    Arabella Barks wrote:

                        Ben,

                        I still suggest adopting the distrust-after.
                        Among the root intermediates that Mozilla
                        plans to remove trust, there is the "AAA
                        Certificates Servies" of Sectigo CA, which is
                        being widely issued and used by a subordinate
                        CA of Cloudflare, namely "Cloudflare TLS
                        Issuing ECC CA 1"
                        (https://crt.sh/?caid=282054, and issued by
                        "SSL.com TLS Transit ECC CA R2"). However,
                        SSL.com TLS Transit ECC CA R2 is just a
                        subordinate CA and not a Root.

                        If Mozilla directly removes the "AAA
                        Certificates Servies" and others, more than
                        12,435,053 websites issued by "Cloudflare TLS
                        Issuing ECC CA 1" will be affected, It has bad
                        impact on the business of CloudFlare's customers.
                        The above is what I have found out through
                        about few minutes of research, based on the
                        sites count and I think it will have a gravity
                        impact.

                        I request the community to conduct an
                        assessment to reduce this impact.

                        On Thursday, April 10, 2025 at 12:10:21 AM
                        UTC+8 Ben Wilson wrote:

                            Thanks for your feedback. Currently, our
                            proposed strategy for handling this
                            particular issue will be to postpone
                            processing the websites trust bit removal
                            from the Chunghwa Telecom ePKI Root CA by
                            two or three months (until approximately
                            Firefox Release 141
                            
<https://whattrainisitnow.com/release/?version=141>).
                            In other words, we do not anticipate using
                            the distrust-after mechanism in the
                            present case.

                            Thanks again,

                            Ben

                            On Wed, Apr 9, 2025 at 9:55 AM Jeffrey
                            Walton <[email protected]> wrote:

                                On Tue, Apr 1, 2025 at 11:03 AM 'Ben
                                Wilson' via
                                [email protected]
                                <[email protected]>
                                wrote:
                                >
                                > Per -
                                
https://bugzilla.mozilla.org/show_bug.cgi?id=1891438#c15:
                                >
                                > "In the interest of transparency,
                                Mozilla received a formal request from
                                Taiwan’s Ministry of Digital Affairs
                                (MODA), dated March 15, 2025,
                                requesting that we delay the removal
                                of the “websites” trust bit for
                                Chunghwa Telecom’s ePKI Root CA, which
                                is currently scheduled to occur on or
                                about April 15, 2025, in accordance
                                with Mozilla’s Root CA Lifecycles
                                Transition Schedule.
                                >
                                > MODA explained that the requested
                                delay is intended to support the
                                ongoing transition of government
                                websites away from certificates issued
                                by CHT’s GTLSCA-G1 subordinate CA. As
                                we understand it, MODA is already
                                implementing a short-term migration
                                plan involving the dual issuance of
                                approximately 12,000 new certificates
                                for government websites—one from
                                Chunghwa Telecom and one from Taiwan
                                CA (TWCA)—to ensure continued
                                availability of government services
                                and minimize user disruption.
                                >
                                > While we have not yet finalized a
                                decision, we are currently contemplating:
                                >
                                > Postponing the removal of the
                                “websites” trust bit;
                                > Implementing a distrust-after date; or
                                > Taking other actions consistent with
                                Mozilla Root Store Policy and
                                ecosystem risk management.
                                >
                                > We note that:
                                >
                                > The ePKI Root CA uses a 4096-bit RSA
                                key, which provides stronger security
                                than other similarly aged root
                                certificates.
                                > Any extension under consideration
                                would be strictly time-bounded (e.g.,
                                not to exceed August 1, 2025),
                                reflecting a short-term accommodation,
                                not a change in long-term policy
                                direction.
                                > Mozilla would retain the right to
                                remove or revoke trust at any time,
                                based on new information or evolving
                                risk factors.
                                >
                                > We welcome feedback on any of these
                                approaches."

                                Please consider avoiding the
                                DistrustAfter strategy. It causes
                                problems for tools which use Google,
                                Mozilla (and friends) curated
                                lists of trusted CAs. The tools
                                include utilities like cURL and Wget.
                                See, for example,
                                <https://github.com/curl/curl/issues/15547>.

                                Jeff

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