Below my suggestions concerning a policy update or guidelines for CAs 
which issue or have already external sub-ordinated CAs. This could be 
also an extension to the Mozilla policy. Here is my initial take:

Plain CAs:

- Obligations and requirements of intermediate CAs shall be clearly 
defined and described in the policy and practice statements of the CA root.
- The root CA must enforce compliance of said policies by intermediate CAs.
- The root CA must guaranty adherence to the minimum requirements of the 
Mozilla CA policy by all issuing CAs in the PKI of the root.
- CAs which are operated by a government agency - or on behalf of a 
government or local authority, who's sole purpose is the bootstrapping 
of licensed CAs according to the respective local legislation shall not 
apply for inclusion, instead the individual CAs in question shall make a 
request for inclusion directly if they wish to do so.
- CAs which don't issue end-user certificates shall not apply for 
inclusion, instead the intermediate CAs shall make a request for 
inclusion directly if they wish to do so.

EV CAs:

- If the intermediate CAs are not audited (answer pending) according to 
the EV guidelines I would suggest to find ways to guaranty adherence of 
the EV guidelines. Possibly marking of the intermediate CAs as EV 
instead of the roots. The purpose of this would be to make sure that 
there won't be any "runaway" CAs which are chained to such an extend 
that control over such sub ordinated CAs by the CA root would be highly 
questionable or even impossible.
- Should auditing of intermediate CA certificates be required (and 
included in the audit reports), no further addition has to be made to 
the current policy, since this is already covered by the latest additions.



I would also like to see an addition concerning physical (security) and 
operational requirements to accepted industry standards (Yes, I know, 
that sounds somewhat undefined). I have intentionally left out a 
reference to name constraints for sub CAs. Feel free to add something in 
that respect (I guess after confirming the current status of NSS etc...).


-- 
Regards 
 
Signer:         Eddy Nigg, StartCom Ltd. <http://www.startcom.org>
Jabber:         [EMAIL PROTECTED] <xmpp:[EMAIL PROTECTED]>
Blog:   Join the Revolution! <http://blog.startcom.org>
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