On 13/05/16 13:41, Richard Barnes wrote:
IIRC, the disclosure requirement is in terms of certificates, and the
disclosure responsibility is on the issuing CA.  So you would have one
disclosure per certificate, and the issuing CA would be responsible.

The Inclusion Policy [1] says that the responsibility is on "the CA that has their certificate included in Mozilla's CA Certificate Program". I don't see a mention of the "issuing CA".

The recent CA Communication said:
"ACTION #2: Beginning with Version 2.1 of Mozilla's CA Certificate Policy, for any certificate which directly or transitively chains to the root certificates you currently have included in Mozilla's CA Certificate Program, which are capable of being used to issue new certificates, and which are not technically constrained as described in Section 9 of Mozilla's CA Certificate Inclusion Policy, you are required to provide public-facing documentation about the certificate verification requirements and annual public attestation of conformance to said requirements. This includes certificates owned by, operated by, or issued by third parties, whether or not those issuing certificates are already part of Mozilla's CA Certificate Program, if they have been cross-signed by a certificate that directly or transitively chains to your root certificate."

IIUC, that last sentence is saying that multiple disclosures are required (one disclosure per root to which the intermediate chains). Have I misread it?


[1] https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/inclusion/

[2] https://mozillacaprogram.secure.force.com/Communications/CACommunicationSurveySample?CACommunicationId=a05o000000iHdtx

Note that you can end up with multiple parents for the same exact
certificate, but that requires that each parent have the same public key --
so if those parents are owned by different organizations, we would have a
problem!

On Fri, May 13, 2016 at 2:08 PM, Rob Stradling <rob.stradl...@comodo.com>
wrote:

Kathleen,

Some NSS built-in roots are cross-certified by other built-in roots.

When an intermediate cert chains to multiple roots, does it need to be
disclosed multiple times (once for each root)?

Or, if it only needs to be disclosed once, then how should we determine
which CA is responsible for disclosing?  (Shortest chain, perhaps?)

Thanks.

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

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