On Fri, Sep 23, 2016 at 6:22 AM, Jakob Bohm <[email protected]> wrote:
> On 23/09/2016 14:29, Kurt Roeckx wrote:
>>
>> On 2016-09-23 00:57, Peter Bowen wrote:
>>>
>>> Kathleen, Gerv, Richard and m.d.s.p,
>>>
>>> In reviewing the WebTrust audit documentation submitted by various CA
>>> program members and organizations wishing to be members, it seems
>>> there is possibly some confusion on what is required by Mozilla.  I
>>> suspect this might also span to ETSI audit documentation, but I don't
>>> know the ETSI process as well, so will leave it to some else to
>>> determine if there is confusion there.
>>
>>
>> So at least 1 thing I miss in those audit reports is which CAs are
>> covered. If you look at the CAs they disclosed, how can we be sure that
>> the audit actually covers that CA? I think the report should cover at
>> least all root and intermediate CAs that are required to be disclosed by
>> Mozilla.
>>
>
> Except those that are covered by separate Audit reports (also
> submitted).  Examples would include cross-signed copies of other root
> CAs (which already submit audit reports), as well as CAs covered by
> submitted audit reports of other parts of the same CA organization (for
> example, StartCOM might be cross-signed by WoSign but audited
> separately, and the WoSign EV SubCA is audited separately under
> stricter rules).
>
> For such certificates it would be enough for the parent CA audit report
> to list them and state that separate audit reports should be checked
> for those (the auditor of the parent CA audit report may not know the
> outcome of the the subCA audit when issuing his report on the parent
> CA).

The lack of inclusion is the implication that you need to do so.
There could be a new criteria that the CA has publicly disclosed (via
XXX?) all CA certificates it has signed, but this is not currently a
WebTrust criteria.

> Of cause the audit of the parent CA should still audit the
> controls that prevent issuing SubCA certificates that are unlikely to
> be compliant, regardless if those controls are "we only sign our own
> in-house SubCAs using a multi-person signing ceremony" or "we sign any
> SubCA that pays a fee and passes a full BR audit by Ernst, Young or
> Deloite".

Exactly the reason I finding it concerning when there is no statement
of assurance of controls around issuance of subordinate CA
certificates.

Thanks,
Peter
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