On 2/12/2008 7:37 PM, Eddy Nigg (StartCom Ltd.) wrote:
> 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...).

In the existing policy, I see only brief mention of removing a
previously approved root certificate (the phrase "to discontinue
including a particular CA certificate in our products" in the first
sentence of Section 4).  I think we need to expand upon that issue.

Examples (plus "and other reasons") should be given for why an approved
certificate loses its approval.

The administrative process for removing a certificate should be
described.  For example, will a Bugzilla report be issued?  How long a
review should be tolerated between proposing the removal and the approval?

To protect uses who still have versions of Mozilla products (and related
products) with a removed certificate, the policy should provide for
listing such certificates along with the reason for their removal.  Both
a permanent list on the Web and notices at both
<news://news.mozilla.org:119/mozilla.announce> and
<news://news.mozilla.org:119/mozilla.dev.tech.crypto> should be used.
Perhaps the policy should authorize a press release.

-- 
David E. Ross
<http://www.rossde.com/>

Go to Mozdev at <http://www.mozdev.org/> for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
more quickly than you can Mozilla Add-Ons.
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