Hello everyone,

Thanks to the CA operators who participated in the recent Mozilla CA
Operator Communication and Survey regarding the proposed Mozilla Root Store
Policy (MRSP) v3.1 changes.

We have now published an anonymized copy of the survey responses on the
Mozilla CA wiki:

*https://wiki.mozilla.org/CA/Communications#May_2026_CA_Communication_and_Survey*
<https://wiki.mozilla.org/CA/Communications%23May_2026_CA_Communication_and_Survey>

Company names and respondent names have been removed. The published
responses are intended to provide transparency into the feedback received
and to assist the community in understanding the issues raised during the
review period.

Based on the feedback received, I have revised sections 3.1.5 and 3.3 of
the draft MRSP:

   - *Section 3.1.5 (Detailed Controls Reports)*
   
<https://github.com/BenWilson-Mozilla/pkipolicy/commit/e2b1c60c8c12251d24a1b9a1a43046c3d76df971>
   - *Section 3.3 (CPs and CPSes)*
   
<https://github.com/BenWilson-Mozilla/pkipolicy/commit/e4505196964a22f2ef5c486d9dfe70e67d321c33>

These revisions are intended to address many of the comments submitted by
CA operators, including questions relating to audit framework flexibility,
confidentiality protections, audit timing, externally-operated subordinate
CAs, CP/CPS documentation structure, incorporation by reference, version
history, certificate profile disclosures, repository requirements, and
protection of security-sensitive information.

In particular, the revised DCR language now clarifies that:

   - Multiple audit frameworks may be used, including ETSI-based reports,
   provided the required information is present;
   - DCRs are not required to be publicly disclosed;
   - Mozilla may request existing DCRs for supervisory review purposes;
   - Confidentiality protections and limited redactions are permitted; and
   - The requirement applies to annual audit periods beginning on or after
   July 1, 2027.

The revised CP/CPS provisions further clarify expectations regarding
implementation commitments, sufficiency of disclosure, incorporation by
reference, documentation structure, certificate and revocation profiles,
version history, and maintenance of current and accurate documentation.

A recurring theme in the survey responses was a request for examples and
implementation guidance rather than additional policy text. In response, I
am preparing companion wiki guidance for both CP/CPS Documentation and
Detailed Controls Reports. The guidance is expected to include illustrative
examples, frequently asked questions, and practical implementation
considerations intended to promote consistent interpretation of the
requirements while preserving flexibility in how CA operators meet them.

Please review the updated draft language and survey responses and provide
any additional comments as soon as practical. My goal is still to complete
the remaining updates and publish MRSP v3.1 with an effective date of June
15, 2026.

Thank you again to everyone who took the time to review the proposed
changes and provide feedback.

Ben Wilson
Mozilla Root Program

On Fri, May 29, 2026 at 12:03 PM Ben Wilson <[email protected]> wrote:

> All,
>
> Thanks to the CA Operators who participated in the recent survey regarding
> the proposed changes for Mozilla Root Store Policy (MRSP) version 3.1.  We
> received substantial, thoughtful, and constructive feedback, which provided 
> useful
> insight into both implementation challenges and areas needing more clarity.  
> We
> are currently reviewing the responses, and I'll be making revisions to the
> draft MRSP v3.1 where appropriate based on that input.
>
> In parallel, I am preparing summaries of the survey results, which I will
> publish on the Mozilla wiki.
>
> Thanks,
>
> Ben Wilson
> Mozilla Root Program
>
>

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