These changes are great Ben. Ship it!

On Wednesday, May 13, 2026 at 11:35:51 AM UTC-7 Ben Wilson wrote:

> Greetings, 
>
> In response to comments from Trev and Roman, I am editing section 3.3.2 
> (Normative References and Incorporation by Reference), which currently 
> reads as follows:
>
> To avoid duplication, divergence, and staleness, incorporation by 
> reference SHOULD be used for shared definitions and externally defined 
> normative requirements (e.g., CA/Browser Forum Requirements, RFCs, 
> documents incorporated by reference therein, corresponding WebTrust or ETSI 
> audit criteria, and other applicable policies).
>
> However, incorporation by reference MUST NOT be used as a substitute for 
> describing CA-specific implementation practices. CP/CPS Documentation MUST 
> clearly identify incorporated documents.
>
> CP/CPS Documentation MAY reference operational, contractual, 
> informational, repository, or technical materials maintained outside the 
> CP/CPS Documentation by the CA operator, Root Programs, the CCADB, 
> standards bodies, or the CA/Browser Forum (e.g., webpages, Subscriber 
> Agreements, validation procedures, or technical appendices), provided that:
>
>    - such materials are clearly identified and publicly accessible where 
>    necessary to understand the CA operator’s practices; their scope and 
>    applicability are clearly described;
>    - the CP/CPS Documentation remains sufficiently complete and coherent 
>    for a reviewer to understand how the CA operator complies with applicable 
>    requirements; and
>    - such references do not alter or supersede applicable requirements.
>
> See 
> https://github.com/BenWilson-Mozilla/pkipolicy/commit/03f638b283d71a0b163056c2998e50b5cb8c6658
>   
> (lines 255-364).
>
> I'm open to further suggestions and refinements.
>
> Ben
>
> On Wed, May 13, 2026 at 1:44 AM 'Roman Fischer' via 
> [email protected] <[email protected]> wrote:
>
>> To add to Trev's list, we have references to:
>>
>>    - Our webpage, document repository and the demo webpages
>>    - CCADB
>>    - ETSI
>>
>>  
>>
>> Regards
>> Roman
>>
>>  
>>
>> *From:* 'Trevoli Ponds-White' via [email protected] <
>> [email protected]> 
>> *Sent:* Dienstag, 12. Mai 2026 23:08
>> *To:* [email protected]
>> *Cc:* Ben Wilson <[email protected]>; Trevoli Ponds-White <
>> [email protected]>; [email protected] <[email protected]>; 
>> Martijn Katerbarg <[email protected]>
>> *Subject:* Re: MRSP 3.1: Issue #s 282 and 295: CP/CPS Documentation
>>
>>  
>>
>> That's fantastic Ben. Great suggestion Martijn I hadn't made that 
>> connection yet but definitely concur. For the documents reference what 
>> about adding this sentence:
>>
>> "*This excludes documents defined by or referenced in the Baseline 
>> Requirements for the applicable certificate type.*"
>>
>> In practice this would mean for TLS certificates all these external 
>> references are allowable:
>>
>>    1. Any RFC, IANA, or NIST resource referenced in the applicable BRs.
>>    2. Subscriber Agreement. Which is defined by in the BRs.
>>    3. Relying Party Agreement. Which is referenced in the BRs. (We 
>>    probably want to fix this in a cleanup ballot because in the BRs we refer 
>>    to this like a defined term but it’s not defined.)
>>    4. The CA/B Forum website.
>>    5. WebTrust Principles and Critieria.
>>    6. CA/B F recommended Github repos. Such as the Debian weak keys.
>>    7. The links for TorProject, Fermat Attack, and Public Suffix List.
>>
>> I'm don't know enough about what other types of external docs other CAs 
>> are referencing to know how restrictive this should be. In addition to 
>> referencing some of those listed above ours also includes a reference to a 
>> privacy policy and the policy pages for the root programs. 
>>
>> On Tuesday, May 12, 2026 at 1:38:24 PM UTC-7 Ben Wilson wrote:
>>
>> That's fine, too. I'll make that change.
>>
>>  
>>
>> On Tue, May 12, 2026, 2:23 PM Martijn Katerbarg <[email protected]> 
>> wrote:
>>
>> Ben, 
>>
>>  
>>
>> While this is feedback we sent on the recent survey, I’ll repeat it here: 
>> For the effective date, is Mozilla willing to consider aligning with 
>> Apple’s policy update proposal, targeting July of 2027?
>>
>>  
>>
>> Both programs are making changes which will require extensive reviews 
>> across multiple CP/CPSes. As we know, incorrections in a CPS can have a 
>> large impact. As such, we worry that a “rush job” on this, is a recipe for 
>> disaster. Additionally, several CAs are also still working on making the 
>> documentation available in MarkDown format, and splitting our general 
>> CP/CPSes into purpose specific CP/CPSes. 
>>
>>  
>>
>> I feel a careful balance of gains verses risk management is warranted 
>> here, hence our request to align with the later date proposed by Apple. 
>>
>>  
>>
>> Regards,
>>
>>  
>>
>> Martijn
>>
>>  
>>
>> *From: *'Ben Wilson' via [email protected] <
>> [email protected]>
>> *Date: *Tuesday, 12 May 2026 at 22:05
>> *To: *Trevoli Ponds-White <[email protected]>
>> *Cc: *[email protected] <[email protected]>
>> *Subject: *Re: MRSP 3.1: Issue #s 282 and 295: CP/CPS Documentation
>>
>> This Message Is From an External Sender
>>
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>> Report Suspicious 
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>>
>>  
>>
>> Hi Trev,
>>
>> Thanks for your comments.  I have revised section 3.3 of the 
>> working draft to add an effective date of October 15, 2026, and also made 
>> other changes.
>>
>> See 
>> https://github.com/BenWilson-Mozilla/pkipolicy/commit/c555615430fd188db394503baad6c62981e15aa8
>>  
>> <https://urldefense.com/v3/__https://github.com/BenWilson-Mozilla/pkipolicy/commit/c555615430fd188db394503baad6c62981e15aa8__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyLQ3Hwdi$>
>> .
>>
>> Thanks again,
>>
>> Ben
>>
>>  
>>
>> On Tue, May 12, 2026 at 12:58 PM 'Trevoli Ponds-White' via 
>> [email protected] <[email protected]> wrote:
>>
>> I like the updates Ben. I have a few comments
>>
>>  
>>
>> 1) 3.3.3 Implementation Commitments" should probably have a further 
>> future date. This policy provides more clarity and people may want to edit 
>> their CP/CPS.
>>
>>  
>>
>> 2) "multiple external documents." This could use some examples or 
>> additional clarity. For example Mozilla has a few places where CAs are 
>> required to "communicate to subscribers" this is generally done with the 
>> Subscriber Agreement not the CP/CPS. Is this saying we need to duplicate 
>> the text that is also in the Subscriber Agreement into the CP/CPS with some 
>> language like "we comply this with this by putting the following in the 
>> Subscriber Agreement..." or is that not considered an external document and 
>> instead some extension of the CP/CPS?
>>
>>  
>>
>> Thanks!
>>
>>  
>>
>> On Friday, May 8, 2026 at 11:23:54 PM UTC-7 Roman Fischer wrote:
>>
>> Hi Ben,
>>
>>  
>>
>> Your suggested wording makes the intention clear to me. And section 7 is 
>> also IMHO very clear and useful to ensure traceability over past versions 
>> of the documents.
>>
>>  
>>
>> Rgds
>> Roman
>>
>>  
>>
>> *From:* Ben Wilson <[email protected]>
>> *Sent:* Freitag, 8. Mai 2026 17:46
>> *To:* Roman Fischer <[email protected]>
>> *Cc:* [email protected]
>> *Subject:* Re: MRSP 3.1: Issue #s 282 and 295: CP/CPS Documentation
>>
>>  
>>
>> Hi Aaron and Roman,
>>
>> Thanks for your feedback and questions. The CCADB has two fields 
>> implicated here:
>>
>>    - the “CA Document Repository” field, which identifies repository 
>>    locations and may contain multiple URLs as a semicolon-separated list; and
>>    - the “Document Link” field(s), which identify the specific URLs for 
>>    the actual CP/CPS documents themselves.
>>
>> Because the CCADB separately tracks the specific document URLs, I am 
>> considering emphasizing those specific document links over the "repository” 
>> concept. In other words, the CCADB still collects the repository location, 
>> which is a useful reference when browsing a CA operator’s website to locate 
>> related CP/CPS documentation, but I think it's less important from a 
>> filing/compliance perspective now that the CCADB stores direct document 
>> links separately.
>>
>> I am currently considering abbreviating the language to something like:
>>
>> “CA operators MUST ensure that CP/CPS Documentation is made publicly 
>> available in a structured, text-based format (e.g. Markdown, AsciiDoc, or 
>> equivalent) and in a manner that preserves publicly accessible version 
>> history. CA operators MUST ensure that the current location (URL) of each 
>> CP/CPS document is accurately disclosed and maintained within the CCADB.”
>>
>> I’ve tried to avoid being overly prescriptive in order to preserve 
>> flexibility.   
>>
>> What are your thoughts?  Will this approach adequately addresses your 
>> concerns, or should we take a different one? 
>>
>> Also, are your concerns related to subsection 7 (document archiving)? 
>> Should that paragraph be edited too?
>>
>> Thanks again,
>> Ben
>>
>>  
>>
>> On Fri, May 8, 2026 at 1:13 AM 'Roman Fischer' via 
>> [email protected] <[email protected]> wrote:
>>
>> I'm a bit confused: Does this mean that the disclosed location should be 
>> the repository (typically a webpage or github repo) where the current and 
>> the archived versions are listed or the URL of the current CP/CPS document 
>> (typically a Markdown file hosted somewhere) or an array of URLs of the 
>> current and previous versions of the CP/CPS document?
>>
>>  
>>
>> Thx
>> Roman
>>
>>  
>>
>> *From:* 'Aaron Gable' via [email protected] <
>> [email protected]>
>> *Sent:* Mittwoch, 6. Mai 2026 04:11
>> *To:* [email protected]
>> *Cc:* Ben Wilson <[email protected]>; Wayne <[email protected]>; 
>> [email protected] <[email protected]>; Aaron Gable <
>> [email protected]>
>> *Subject:* Re: MRSP 3.1: Issue #s 282 and 295: CP/CPS Documentation
>>
>>  
>>
>> I think that's much better. One potential issue: if a CA maintains a 
>> separate CP and CPS (I believe still acceptable in v3.1), they could be in 
>> different GitHub repositories. This would make disclosing a single URL in 
>> the "Document Repository" field difficult, as it could only point to one or 
>> the other.
>>
>> On Monday, April 27, 2026 at 1:08:54 PM UTC-10 Ben Wilson wrote:
>>
>> What about this formulation of Item 2 under MRSP section 3.3?
>>
>> 2. CA operators MUST maintain CP/CPS Documentation in a structured, 
>> text-based format suitable for version control (e.g., Markdown, AsciiDoc, 
>> or equivalent), host such documentation in a publicly accessible repository 
>> or equivalent system that provides publicly accessible version history, and 
>> ensure that the current, publicly accessible locations (URLs) of that 
>> CP/CPS documentation are disclosed in, and kept up to date within, the 
>> CCADB “Document Repository” field.
>>
>>  
>>
>> Thanks,
>>
>>  
>>
>> Ben
>>
>>  
>>
>> On Sun, Apr 26, 2026 at 11:47 AM Ben Wilson <[email protected]> wrote:
>>
>> Hi Aaron,
>>
>> Thanks for these comments.  
>>
>> You’re right that the draft hasn't explicitly addressed location of 
>> documentation disclosure and archiving.
>>
>> One idea is to leverage the CCADB field “Document Repository” or to 
>> create an adjacent field to specify archival locations.
>>
>> I am considering adding the following requirement to MRSP Section 3.3:
>>
>> “CA operators MUST ensure that the location (URL) of their CP/CPS 
>> Documentation is disclosed and maintained in the CCADB 'Document 
>> Repository' field.”
>>
>> However, that alone will be inadequate. We'll need to amend the CCADB 
>> Policy and/or provide guidance for use of the “Document Repository” field 
>> (and possibly add another field for archival locations) to clarify the use 
>> of the(se) field(s) and ensure uniformity and consistent implementation. 
>> For example:
>>
>> “The ‘Document Repository’ field MUST contain one or more URLs that 
>> provide access to the CA Owner’s current CP/CPS Documentation. Where CP/CPS 
>> Documentation is maintained in a version-controlled repository, the URL 
>> MUST reference the repository or a stable landing page that clearly 
>> identifies the current version and provides access to prior versions or 
>> version history. CA Owners MUST ensure that this field is kept accurate and 
>> up to date.”
>>
>> What are everyone's thoughts on this, and Is another CCADB field needed 
>> to point to the archival repository (even if they are both in the same 
>> location)?
>>
>> Ben
>>
>>  
>>
>>  
>>
>> On Fri, Apr 24, 2026 at 1:11 PM Aaron Gable <[email protected]> 
>> wrote:
>>
>> I concur, the changes related to CPS content seem good and don't seem 
>> onerous.
>>
>>  
>>
>> I have one minor concern: Section 3.3(2) says that CAs must keep their 
>> CP/CPS Documentation in markdown in a public repo, but doesn't say how the 
>> CA shall disclose the location of such. Linked from our website (as the 
>> current version of the requirements says)? Linked from our Repository? 
>> Disclosed in CCADB? Paragraph (7) of the same section does say that CAs 
>> shall "maintain links to all historical versions", but it doesn't say 
>> where, and my interpretation of that paragraph is that it is about 
>> preventing bit-rot (i.e. old links have to continue working).
>>
>>  
>>
>> Thanks,
>>
>> Aaron
>>
>>  
>>
>> On Wed, Apr 22, 2026 at 12:37 PM Wayne <[email protected]> wrote:
>>
>> Having read the comparison of proposed changes nothing jumps out as a 
>> stepback. Overall the changes seem to improve clarity, transparency, and 
>> are overall a step forward for the industry.
>>
>>  
>>
>> Thanks everyone for your hard work in getting us this far.
>>
>>  
>>
>> - Wayne
>>
>>  
>>
>> On Wednesday, April 22, 2026 at 8:23:40 PM UTC+1 Ben Wilson wrote:
>>
>> All,
>>
>> This thread begins discussion of proposed updates to the Mozilla Root 
>> Store Policy (MRSP) dealing with Certificate Policy/Certification Practice 
>> Statement (CP/CPS) Documentation. Throughout the MRSP, the term, “CP/CPS 
>> Documentation,” will replace the phrase “CP, CPS, or combined CP/CPS”.
>>
>> Over time, CP/CPS documentation has increasingly relied on incorporation 
>> by reference to the Baseline Requirements, which seems to reduce visibility 
>> into CA-specific implementation details. Also, concerns have been expressed 
>> in community discussions (e.g. the 2025 Roundtable, dev-security-policy, 
>> and CCADB Public 
>> <https://urldefense.com/v3/__https://groups.google.com/a/ccadb.org/g/public/c/iZg_253IZfo/m/eC8kQnOlBgAJ__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyI8p4FJk$>)
>>  
>> regarding the level of detail provided in CP/CPS documentation. The 
>> proposed changes are intended to improve the extent to which CP/CPS 
>> documentation can be used to understand and evaluate a CA operator’s actual 
>> practices, rather than serve as a high-level, referential document.
>>
>> The proposed changes primarily address the following GitHub issues:
>>
>>    - #295 
>>    
>> <https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/issues/295__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyHkTdrDj$>
>>  – 
>>    Revisions to MRSP 3.3
>>    - #282 
>>    
>> <https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/issues/282__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyDWKAZ6o$>
>>  – 
>>    Require Markdown/AsciiDoc for CP/CPS documentation
>>
>> Here is comparison of proposed MRSP 3.1 (as of today) vs. current MRSP v. 
>> 3.0: 
>> https://github.com/mozilla/pkipolicy/compare/3b7d84f5c9708cf6be9655319825d60ea338eca4...ad8e1766be6e0e9a93a64b0b71506ae923086ec5
>>  
>> <https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/compare/3b7d84f5c9708cf6be9655319825d60ea338eca4...ad8e1766be6e0e9a93a64b0b71506ae923086ec5__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyKrwEy1l$>
>> .
>>
>> Here is the working branch for MRSP v. 3.1 (working draft, subject to 
>> change):  
>> https://github.com/BenWilson-Mozilla/pkipolicy/blob/3.1/rootstore/policy.md 
>> <https://urldefense.com/v3/__https://github.com/BenWilson-Mozilla/pkipolicy/blob/3.1/rootstore/policy.md__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyNBSckQq$>
>> .
>>
>>  
>>
>> *Overview of Proposed Changes*
>>
>> *1. Sufficiency and Clarity of Disclosure -  **#295* 
>> <https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/issues/295__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyHkTdrDj$>
>>
>> The current MRSP requires that CP/CPS documentation provide sufficient 
>> information to determine compliance. In practice, however, many CP/CPS 
>> documents have relied heavily on incorporation by reference (e.g., citing 
>> Baseline Requirements sections) without clearly describing how those 
>> requirements are satisfied with implementation.
>>
>> The proposed changes clarify that CP/CPS documentation must describe the 
>> CA operator’s *implementation* of applicable requirements, not merely 
>> identify them.
>>
>> Under this approach:
>>
>>    - *3.3.1*  CP/CPS documentation is expected to provide CA-specific 
>>    detail sufficient for a technically competent reviewer to understand how 
>>    validation, issuance, revocation, and related processes are actually 
>>    performed.
>>    - *3.3.2*  Incorporation by reference remains permissible for 
>>    normative obligations and shared definitions, but it cannot substitute 
>> for 
>>    disclosure of CA-specific practices.
>>    - *3.3.3*  Documentation must be explicit, bounded, and testable 
>>    where feasible, enabling meaningful audit, review, and comparison across 
>> CA 
>>    operators.
>>    - *3.3.4*  Reviewers should not be required to reconstruct 
>>    operational practices by correlating multiple external documents.
>>    - *3.3.5*  CP/CPS documentation must contain or clearly reference 
>>    certificate, CRL, and OCSP profiles (separate, versioned companion 
>>    documents are allowed where appropriate).
>>    - *3.3.6*  CP/CPS documentation must reflect current operations with 
>>    substantive changes traceable through version history and changelogs.
>>
>> The intent is to make CP/CPS documentation a reliable and self-contained 
>> description of how a CA operates in practice, particularly in areas where 
>> the Baseline Requirements or other standards allow discretion.
>>
>> *2. Documentation Format and Versioning - **#282* 
>> <https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/issues/282__;!!J5K_pWsD!3Hn4r1DdAtKrFhqLq-5gvw1-0OT2ThG_woxugee0xEHGeLrS9Qb1_PEp2w0isN2zL-la5qxJohXZFzuTkORHL8aUaeZdyDWKAZ6o$>
>>
>> Also proposed (in Item 2 of MRSP 3.3) are requirements to maintain 
>> publicly accessible CP/CPS documentation in a structured, text-based format 
>> (e.g., Markdown, AsciiDoc, or similar), with version history.  It is 
>> proposed that the requirement to publish CP/CPS documentation on the CA 
>> operator’s website be removed, to allow for alternative publication models 
>> (e.g., version-controlled public repositories). CA operators may continue 
>> to publish PDF versions on their websites if they choose.
>>
>> These edits are intended to promote CA operator consistency in how such 
>> documentation is maintained and published and to support more efficient 
>> review, comparison, and automation. Rather than prescribing a single tool 
>> or platform, the requirement focuses on characteristics: structured text, 
>> version control, and publicly accessible history.
>>
>> Feedback on the proposed direction and draft language is welcome.
>>
>> Thanks,
>> Ben Wilson
>> Mozilla Root Program
>>
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