In no particular order. Mostly nits.

Sec 3.2, I understand the concern of ACME being a third-party dependency, while 
the origin is not really.  Perhaps a sentence of explanation why it is, would 
help.  Or maybe just say “with an ACME server”  And then mention ACME in the 
origin?

Sec 4, the “valid_time” says MUST NOT exceed seven days.  That’s relative to 
client and server concept of “now,” right?  See note below.

Sec 4.1.1 should say that SignatureSchemeList is the same as the one in RFC 
8446.  I’d prefer to see the duplication removed.

Sec 4.2 doesn’t seem to agree with the complete ASN1 in Appendix A.  The latter 
has DelegatedCredentialExtn which is mentioned in prose and a TBD in 4.2  
Perhaps a comment or some other words to tie them together?  Or does that issue 
just go away when IANA does the registration?

Sec 7.5, I would put the incognito mode in a separate paragraph to call it out 
more clearly.

Note below:
It could be possible for the server to pre-generate delegated credentials and 
either hold them or distribute them. I think that is worth mentioning, with the 
caveat that they cannot be used until within seven days of “now”

Tnx.

                /r$
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