Hi Erwann,
Thank you for your clarifications. We analysed it, and we add Authority 
Key Identifier extension to our CRLs. As it it mentioned in s. 5.2.1 RFC 
5280 “this extension is  especially useful where an issuer has more than 
one signing key, either due to multiple concurrent key pairs or due to 
changeover”.  We based the value of this extension on issuer name and 
serial number. We checked that GoDaddy distinguishes CRLs in the same way.
The CRL for the newer CA certificate is available now here 
http://www.elektronicznypodpis.pl/crl/trusted_ca_2013.crl. CRL for the 
elder CA certificate will be available tomorrow.

Regards,
Przemek



Od:     Erwann Abalea <[email protected]>
Do:     [email protected], 
Data:   2014-10-03 20:19
Temat:  Re: Re: KIR S.A. Root Inclusion Request
Wysłane przez:  "dev-security-policy" 
<dev-security-policy-bounces+certificates=kir.com...@lists.mozilla.org>



Le vendredi 3 octobre 2014 15:22:23 UTC+2, Certificates a écrit :
> We filed an application for Mozilla Root Certificate Program in December 

> 2012. We applied for inclusion existing Root CA with one sub CA. After 
> applying we received from Mozilla information that it is necessary to 
meet 
> additional requirements from BR. The issue needed to be improved was to 
> add to subCA certificate OCSP extension. We were not able to do it 
through 
> simple renewal of subCA certificate. We generated new pair of keys for 
CA 
> and Root CA issued new certifcate with required OCSP extension.This 
issue 
> was explained during first phase of our inclusion process and you can 
find 
> more detailes here: https://bugzilla.mozilla.org/show_bug.cgi?id=817994

That's right. You generated a new key pair and a new certificate for the 
CA. You didn't generate a new CA.

> Each CA certificate has different pair of keys, serial numbers and AKIs. 

> They generate separate CRLs  and provide individual OCSP service, There 
> are still valid certificates issued under the old CA, and that's why 
both 
> CAs issues separate CRLs. 

This is one CA with 2 certificates, and 2 key pairs. One CA, responsible 
for the whole population of certificates it produced, either attached to 
the first or the second CA certificate. You can have 2 CRLs, they MUST 
either be:
 - limited in their scope (IDP extension, for example), and each one will 
contain revoked certificates covered by this scope; CRLNumber can be from 
2 different sequences
 - full scope (no IDP or equivalent partitioning extension), and each one 
MUST provide revocation status for the entire population of certificates 
issued by this CA; CRLNumber MUST be taken from the same monotonically 
increasing sequence, if CRLNumber has the same value in both CRLs then 
dates MUST be equal and revokedcertificates list MUST also be equal (if 
CRLNumber are different, the differences in revokedcertificates list can 
be explained because time passes)

> Each user's certificate has 
> cRLDistributionPoints extension with the URLs to the apropriate CRLs.
> In our opinion there is no danger of replacing CRL lists.
> During CRL verification process it is checked who issued CRL and if the 
CA 
> issuer has valid certificate issued by Root CA . That's way it is 
> impossible during correct CRL verification process to use fake CRL. If 
an 
> application does validation in incorrect way, it will be done incorrect 
> regardless of whether we have 2 CA certificates or more. 

You're wrong.

Imagine the following situation:
Root CA issues 2 certificates for one CA, one of the certificates (C1) has 
the keyUsage:keyCertSign set, the other one (C2) has the keyUsage:CRLSign 
set.
The intermediate CA signs subscriber certificates with the private key 
corresponding to C1 certificate, and it signs CRLs with the private key 
corresponding to C2 certificate.
An RP wants to verify the status of some subscriber cert, after having 
validated the chain up to the root. It downloads the CRL, verifies that it 
is signed by the public key contained in C2 (it knows C2), and checks that 
the subjectName of C2 is equal to the subjectName of C1 (whence, that C1 
and C2 are part of the same CA).
That's a valid situation, extendable to C1 and C2 having both 
keyUsage:keyCertSign and keyUsage:CRLSign set, which is exactly the 
situation you're in.

I suggest you read RFC5280 section 6.3.3 in detail, steps (b)(1) (second 
sentence), (f), and (g).

> Regarding qualified certificates, and the QCA certs. The QCA certificate 

> are issued by The National Certification Centre (Polish Root CA) managed 

> by Ministry of Economy in accordance with the polish act on the 
electronic 
> signature. The validity period of the CA certifcates is 5 years, the 
users 
> can be valid max for 2 years. That's why every three years we receive 
new 
> CA certificate. All CA certificates are issued for new pair of keys . 
One 
> of Polish QCA which is included in Mozilla Root Certificate Program work 

> in exactly the same way as we do.

Don't import those bugs in the TLS space, please ;)

That should tell something about the value of these audits, or about the 
quality of the auditors.
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