On Tue, March 10, 2015 11:33 am, Gervase Markham wrote:
>  The idea of forcibly constraining government CAs to issue for their own
>  TLDs is, to me, a lot more plausible. For one thing, many government CAs
>  don't have the same audits that non-governmental CAs do.
>
>  The difficulty here is defining "governmental", particularly in
>  countries where the "N" in "NGO" is silent.

I think you touched on what I was (somewhat intentionally) skirting.

Currently, the Mozilla inclusion policy allows several audit schemes
- ETSI TS 101 456 v1.4.3+
- ETSI TS 102 042 v2.3.1+
- ISO 21188:2006
- WebTrust Principles for CAs 2.0+ & WebTrust SSL BRs v1.1+
- WebTrust Principles for CAs EV 1.4+

Now, ISO 21188 is a bit anachronistic. I'm surprised we still allow that,
and none of the current included CAs follow that, and I don't think anyone
would miss it if it was dropped.

WebTrust is handled by AICPA/CPA Canada , and the list of global
practitioners is at
http://www.webtrust.org/licensed-webtrust-practitions-international/item64419.aspx
. Of course, anyone can become licensed, per
http://www.webtrust.org/signing-up-for-the-trust-services-program/item64422.aspx

ETSI audits are a bit different. Like WebTrust, a set of criteria are
developed (derived) from the CA/Browser Forum requirements. These are then
enshrined into the ETSI TS guidelines. These guidelines then become
incorporated into local legislative frameworks, which is also responsible
for establishing the auditor qualifications. This is already a mess for
those familiar with it, as some ETSI TS adopting countries have not set up
qualified auditors, and thus CAs within that country need to get audits
from qualified international practitioners. A better summary can be seen
on https://cabforum.org/2014/10/16/ballot-135-etsi-auditor-qualifications/

I mention all of this because it's easy to suggest that the ETSI TS
framework allows for governments to set up their national accreditation
body to allow an NGO-but-really-GO to perform the audits. It's also true
that many of the recent issues have been with ETSI TS-audited entities.

However, a quick scan of https://wiki.mozilla.org/CA:IncludedCAs shows
that there are plenty of government CAs (e.g. Government of Hong Kong,
Government of Spain, Government of Hong Kong) are WebTrust audited, and by
Big Firms (whether that increases or decreases your trust is a different
matter), just as there are a large number that are ETSI TS audited.

Why do I say all this? If you wanted to argue that government CAs don't
have the same audits as non-government CAs - a question of ETSI vs
WebTrust - one solution would be to simply disallow ETSI audits, on the
basis that the government operating the CA gets to (effectively, even if
not in principle) define the audit rigor. I'm sure Erwann would chime in
on why that might be unwise, but it does highlight that if we really do
believe that government CAs are not audited to the same level as
non-governmental CAs, then shouldn't we try to reduce the audit
discrepancy, rather than try to limit the issuance? Wouldn't that serve
more users AND offer a more agile path for future changes?

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