I opened PRs for my other comments, but this one is not editorial.

There's a long list of checks to be run by the CA for account key roll-over, and the current check #8 is "Check that the “newKey” field of the key-change object also verifies the inner JWS." I think that requiring that "newKey" is bitwise identical to the inner "jwk" is both simpler and a stricter check. In principle there may be two different public keys that verify the same signature, but I don't think we want to see such a case here.

Thanks,
    Yaron

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