Hi Aaron,

I tried to track these changes separately, but after merging them into my
3.1 branch I’ve been working from a single branch. To make review easier,
here are the separate branches:
https://github.com/BenWilson-Mozilla/pkipolicy/branches

Relevant issues are: 291, 292, 293, 294, 295, 298, 299 (not yet merged into
3.1), and this one:
https://github.com/BenWilson-Mozilla/pkipolicy/tree/audit-related-issues

You should be able to use GitHub’s “Compare” feature to view each branch
against MRSP 3.0 directly (the link is found in "This branch is x commits
ahead of mozilla/pkipolicy:master"), which may help isolate the changes.

Please let me know if generating more specific comparison links would be
useful.

Thanks,

Ben

On Fri, Apr 24, 2026 at 1:17 PM Aaron Gable <[email protected]> wrote:

> Both of these changes look good to me. It's a bit difficult to isolate
> them in the whole-file diff; it would be great if each of these changes
> came with its own standalone diff, but I totally understand the difficulty
> of disentangling all of that.
>
> Aaron
>
> On Thu, Apr 23, 2026 at 3:16 PM 'Ben Wilson' via
> [email protected] <[email protected]> wrote:
>
>> 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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>> .
>>
>

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