On Thu, Jun 5, 2025 at 3:54 PM Jeremy Rowley <[email protected]> wrote:

> Hi Mike,
>
> I didn't hear any disagreement on the call that the  current policy
> mandates revocation for a CPS misalignment. I'm also not sure that the
> conversation was about Microsoft as that was a cert profile question, not
> just a typo.
>
I am mixing my venues, apologies. Microsoft's CPS error has been described
(minimized) as "a typo" elsewhere, and I inappropriately carried that over
to this discussion. My apologies to the readers and to Microsoft.

> Instead, I would offer them as an SLA to the agreement or similar
> practice. If you violate one of those, the customer gets a credit instead
> of a revoked cert. The CA still shows that they are doing more than the
> minimum but they don't risk revocation if a control fails.
>
This doesn't make sense to me. Many of the items in CPSes (whether they
exceed the BRs or not) are commitments to the relying party about how the
certs are generated or protected. And it's for things that aid the relying
parties that I want to see CAs exceed the BRs in the first place: tighter
controls, shorter validity, etc. How does a relying party "get a credit" if
they rely on a certificate property specified in the CPS that turns out to
not hold, because the CPS was incorrect? That certificate will continue to
carry the misleading characteristic for the duration of its validity, which
is why we want to see its validity terminated.

The CA *isn't* doing more than the BRs if relying parties can't expect that
those extra things apply to every certificate claiming so. They're *trying*
to do more, and *maybe* you can trust that a given certificate has the
properties that its linked CPS claims. If the CPS isn't a reliable
reference for the practices under which the certificate was issued, then
let's take that link out of the certificate entirely and replace it with
inline fields for whatever "important" (read: revocation-worthy if
mismanaged) attributes are needed.

The right path isn't to make CPS errors into "diet incidents" distinct from
other errors related to attributes of certificate issuance. It's to make
revocation simple and painless so that we don't have CAs "forced" to delay
the revocation of millions of inaccurate certificates, due to a failure to
implement best practices advocated by their own organization (like CRL
sharding). I'm referencing Microsoft here again because they are a fresh
example, but they are definitely not alone in having cases of delayed
revocation that were preventable through diligent application of the
practices the community has learned through painful lessons.

We heard the same "it is a wafer-thin error, don't make us do the thing for
which we have ill-prepared ourselves and our Subscribers" complaint about
country codes and OIDs and fields being lowercase or uppercase--basically
anything else that isn't a straight-up key material leak. The underlying
principle remains the same: if it's not important, don't put it (including
by reference) in the certificate in the first place. But the *entire point*
of the dance we do with CAs and CT and validity restrictions and revocation
and paid-for-by-the-auditee-but-that's-another-thread WebTrust audits and
*even having BRs* is this: relying parties can rely on the assertions made
by the certificate if it is valid and the issuance chain can be verified.
If that's not going to hold, then there really is no point and we can let
ssh-style cert continuity suffice for the web instead.

Mike

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