+1. - especially on how CPS docs need to evolve.

On Sat, Jun 7, 2025 at 3:33 PM Ryan Hurst <[email protected]> wrote:

> Aaron's "90 days + 1 second" example perfectly illustrates the point I was
> making originally. This wasn't a documentation typo - it revealed a
> fundamental gap between intended practice and actual implementation. The
> response of changing the CPS to "less than 100 days" is exactly the race to
> the bottom I'm concerned about.
>
> When Aaron says "we can't ever say 90 days in our CPS ever again," that's
> the perverse incentive in action. We're pushing CAs to make their public
> commitments vaguer rather than pushing them to invest in systems that
> ensure those commitments are reliable. This is the problem we need to fix
> with better processes and automation, not with less enforceable and less
> useful governance.
> The thread also reveals a troubling pattern.
>
>  We hear about "good faith errors" and inevitable human mistakes in this
> space constantly, yet this is an industry that has automated domain
> validation, linting of issued certificates, logging all issuance on the web
> via certificate transparency, and manages very large-scale cryptographic
> operations for the world. The claim that policy compliance checking can't
> be similarly automated doesn't hold up to scrutiny.
>
> What we need is to stop treating CPSs as compliance artifacts written
> after the fact and start making them operational documents that sit at the
> center of how CAs work. A properly designed CPS should be machine-readable
> on one side - directly governing issuance systems and preventing the very
> mismatches we're debating - while remaining human-readable on the other for
> auditors and relying parties. This is actually possible today; we just need
> to care enough to do it.
>
> After 30 years in this space, I can't look at most CPSs and understand
> what a CA actually does. But instead of accepting this as inevitable, we
> should be demanding that these documents serve their intended purpose:
> clearly communicating operational reality to everyone who needs to
> understand it.
>
> There are 8 billion people depending on this system. Are we really going
> to allow fewer than 50 root CAs to keep treating their public commitments
> as legal paperwork instead of operational specifications?
>
> The solution isn't weaker enforcement - it's making CPSs the living center
> of CA operations, where policy drives practice instead of scrambling to
> document it afterward.
>
> Ryan
>
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