On Wed, Aug 13, 2014 at 1:44 PM, Ryan Sleevi
<[email protected]> wrote:
> On Wed, August 13, 2014 12:41 pm, Peter Bowen wrote:
>>  On Wed, Aug 13, 2014 at 11:16 AM, Kathleen Wilson <[email protected]>
>>  wrote:
>> > 2) BR point-in-time audits may not be sufficient.
>> >
>> > https://wiki.mozilla.org/CA:CertificatePolicyV2.1#Time_Frames_for_included_CAs_to_comply_with_the_new_policy
>> > "Any Certificate Authority being considered for root inclusion after
>> > February 15, 2013 must comply with Version 2.1 or later of Mozilla's CA
>> > Certificate Policy. This includes having a Baseline Requirements audit
>> > performed if the websites trust bit is to be enabled. *Note that the
>> > CA's
>> > first Baseline Requirements audit may be a Point in Time audit.* "
>> >
>> > We could change that to say that the first BR audit may be performed
>> > over a
>> > minimum of 3 months, and include testing of issuance and infrastructure.
>> > i.e. If it is the CA's first BR audit (because they were not in the
>> > program
>> > and did not know about the BRs) then the audit should cover 3 months,
>> > and
>> > the certificates/CRLs/OCSP-responses issued during that time must be
>> > evaluated against the BRs.
>> >
>> > Would this help? i.e. Is it needed in addition to proposal #1?
>>
>>  It seems there two reasons that CAs might get a point in time
>>  readiness assessment (PITRA) rather than a period of time audit:
>>
>>  2) They don't yet issue certificates.  If an organization is creating
>>  a brand new CA, there is no history of operation to be audited, so the
>>  only thing an auditor can perform is a PITRA.  It is very possible
>>  that the CA will not start issuing certificates until they are
>>  accepted into the Mozilla program.  I think AffirmTrust's application
>>  a couple of years ago demonstrated this scenario.
>>
>>  It seems reasonable to continue to accept the PITRA for CAs that are
>>  not yet issuing certificates. This should be different than handling a
>>  CA that has issued certificate which do not follow the BR.
>>
>>  Thanks,
>>  Peter
>
> For 2, it seems a PITRA prior to the inclusion request, but that there may
> need to be some monitoring phase after the request, and then an audit,
> like Kathleen proposed.
>
> For example, to ensure that OCSP responses are being handled properly
> (e.g. not returning Good, etc), that the infrastructure is correct. A
> PITRA, in an ideal world, would be performing these basic RFC 5280 and BR
> compliance checks, but I suspect auditors may not be fully assessing the
> conformance to technical requirements, and instead assessing assertions of
> conformance to technical requirements (assertions which are,
> unfortunately, more false than not)

For the second case, would it make sense to formalize that all three
audits (WebTrust for CA, WebTrust for BR, WebTrust for EV) can be a
point in time readiness assessment initially and require that the CA
have a period of time audit after operating for N months/days?
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