The only criteria on the Webtrust BR audit
(http://www.webtrust.org/homepage-documents/item27839.aspx) is section 11.
Since the BRs will only apply to certificates issued since the last audit,
and the MS policy prohibited issuance after Dec 2010, there shouldn't be
many/any audits with a qualification because of non-revoked 1024 bit certs. 

-----Original Message-----
From: dev-security-policy
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert.com@lists.mozilla
.org] On Behalf Of Jeremy Rowley
Sent: Wednesday, December 11, 2013 6:01 PM
To: 'Rob Stradling'; 'Kathleen Wilson';
mozilla-dev-security-pol...@lists.mozilla.org
Subject: RE: Exceptions to 1024-bit cert revocation requirement

The requirement is from Mozilla's policy, not the BRs:
https://wiki.mozilla.org/CA:MD5and1024

Note that the Microsoft policy doesn't require revocation.  Instead, they
required all CAs to stop issuing 1024 bit certs as of Dec 31, 2010
(http://technet.microsoft.com/en-us/library/cc751157.aspx).  The
certificates are expiring naturally.

Jeremy

-----Original Message-----
From: dev-security-policy
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert.com@lists.mozilla
.org] On Behalf Of Rob Stradling
Sent: Wednesday, December 11, 2013 5:44 PM
To: Kathleen Wilson; mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Exceptions to 1024-bit cert revocation requirement

On 12/12/13 00:25, Kathleen Wilson wrote:
<snip>
>  From Rob:
>> Kathleen, are you saying that "must expire by the end of 2013" is a 
>> "revocation requirement" ?
>>
>> Expiration != Revocation.
>>
>> Is there actually a requirement that says "By the end of 2013, CAs 
>> MUST revoke all unexpired certificates with <2048-bit RSA keys" ?
>> If so, where is it written and when was it communicated to the CAs?
>>
>> (If it's not actually written anywhere, then can you actually enforce
>> it?)
>
> In BR Appendix A
>
> Subscriber Certificates
> Minimum RSA modulus
> "Validity period ending on or before 31 Dec 2013"
> 1024
> "Validity period ending after 31 Dec 2013"
> 2048

Sure, and BRs Section 13.1.5 says:
   "The CA SHALL revoke a (Subscriber) Certificate within 24 hours if
    ...
    9. The CA is made aware that the Certificate was not issued in
      accordance with these Requirements..."

Sorry, I should have mentioned that I'm thinking primarily about long-lived
certificates that were issued before the BRs became effective.  BRs Section
1 says:
   "Except where explicitly stated otherwise, these requirements apply
    only to relevant events that occur on or after the Effective Date."

Where is it written that <2048-bit certs that predate the BRs need to be
revoked by end of 2013?

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online
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