All,

This thread begins discussion of proposed updates to the Mozilla Root Store
Policy (MRSP) relating to CA operational reporting in a "timely manner" (Issue
#292 <https://github.com/mozilla/pkipolicy/issues/292>) and alignment of
the MRSP with external policy frameworks (Issue #293
<https://github.com/mozilla/pkipolicy/issues/293>).

These changes are intended to improve clarity and consistency in how CA
operators meet their reporting obligations, particularly with respect to
the CCADB, and to better align MRSP requirements with the CCADB Policy and
the CA/Browser Forum’s requirements documents. The goal is to reduce
ambiguity, eliminate overlapping or inconsistent requirements, and
reinforce expectations for CA reporting of accurate and current operational
data.

Again, here is a comparison
<https://github.com/mozilla/pkipolicy/compare/3b7d84f5c9708cf6be9655319825d60ea338eca4...ad8e1766be6e0e9a93a64b0b71506ae923086ec5>
of the proposed MRSP v3.1
<https://github.com/BenWilson-Mozilla/pkipolicy/blob/3.1/rootstore/policy.md>
(working draft, subject to change) vs. the current MRSP v3.0
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>
.

*Overview of Proposed Changes*

*Reporting Obligations and Timeliness – #292
<https://github.com/mozilla/pkipolicy/issues/292>*

Section 7.3 (Removals) is updated to replace the existing reference to
failure to act in a “timely manner” with more explicit language tied to
CCADB and policy compliance expectations.  Under the proposed revision:

“Repeated failure to provide required notifications or updates in the
CCADB, or to otherwise comply with Mozilla or CCADB Policy requirements for
maintaining accurate and current information, SHALL be grounds for
disabling a CA operator’s root certificates or removing them from Mozilla’s
root store.”

This change is intended to:

   - Align the MRSP with the CCADB Policy, which already defines
   expectations for timeliness and data maintenance, and hence avoid
   maintaining separate or potentially inconsistent timing requirements within
   the MRSP; and
   -

   Emphasize that ongoing accuracy and completeness of operational data is
   a core compliance obligation.


*2. Policy Alignment and Order of Precedence – #293
<https://github.com/mozilla/pkipolicy/issues/293>*

Clarifications are added to address how the MRSP interacts with other
applicable requirements, including the CCADB Policy and CA/Browser Forum
guidelines.

A new sentence in section 2.1 provides an order of precedence. In the event
of inconsistency between the MRSP and other applicable requirements, the
MRSP takes precedence. However, where the MRSP does not explicitly resolve
an inconsistency, then the most restrictive applicable requirement applies,
unless otherwise specified.

Additionally, where the MRSP had more specific or duplicative text, it was
removed if the subject was already addressed in the CCADB Policy or
CA/Browser Forum requirements.

These changes are intended to:

   - Provide a clear framework for resolving conflicts across multiple
   governing documents;


   - Reduce redundancy within the MRSP; and


   - Rely on external policies where they already define detailed
   operational requirements, while preserving Mozilla’s authority to impose
   stricter or additional requirements where necessary.


Feedback on the proposed direction and suggestions on the draft language
are welcome.



Thanks,

Ben Wilson

Mozilla Root Program

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