Dear Peter,


I am deeply in ETSI process, so I can give info some info:



Formerly the ETSIs are based on

*        102042 for CAs

*        101456 for CAs issuing qualified certificates (refernces frequently 
the 102042)

o   BRG and EV is referenced from them for SSL and EV SSL certificate issuance.



The new version of these : (2016-02) (these are based on the 910/2014/EC 
regulation, which makes a common EU market.)

*        319411-1 for CAs

*        319412-2 for CAs issuing qualified certificates (refernces frequently 
the 319411-1)

o   319401 is referenced from them for technical requirements (technical 
requirements from 102042 and 101456 were ripped of into this documents)

o   319412-1 ,-2, -3, -4, -5 referenced from them for certificate profiles

o   BRG and EV is referenced from them for SSL and EV SSL certificate issuance.



For EU CAs the Microsoft forces to move to ETSI audit instead Webtrust.



The ETSI audit checks:

*        that the certificate issuance systems and environment are compliant 
with the technical or requirements. (against 319401)

*        that the certificate profiles meet the requirements (against 319412s)

*        the CP/CPS and the practice of issuance compliant with the 319411-1 
(and for qualified certificates with 319411-2)

o   the 319411-1 and 319411-2 defines various Certification policies, and rules 
for them.

LCP, NCP, NCP+, DVCP, IVCP, OVCP, EVCP, and also the new qualified ones (qcp-n, 
qpc-l, qcp-n-qscd, qcp-l-qscd, qcp-w)

For DVCP, OVCP, IVCP, OVCP they references BRG and EVGL (and also for qcp-w, 
which looks like a chimera for me :) )



At the end of audit each issuing subcas are checked against the compliance with 
issuing policies, profiles, and technical requirements.

Of-course the ETSI report, or its Annex also includes the whole list of the 
subordinates too.

Also the Microsoft doesn't accepts audit report without the subordinate list, 
so its mandatory nowadays.



I think what is important to add the 319411-1 and -2 to the actual acceptable 
audit requirements, because the MS ask for this, and it older version (119411 
included in the 2.3 proposal)



At october I would like to upload our new audit reports to Salesforce, which 
are made aganst the 319411-s.

üdvözlettel //sincerelly yours,
Viktor Varga
Netlock
chief architect











-----Original Message-----
From: dev-security-policy 
[mailto:dev-security-policy-bounces+varga.viktor=netlock...@lists.mozilla.org] 
On Behalf Of Peter Bowen
Sent: Friday, September 23, 2016 12:57 AM
To: [email protected] 
<[email protected]>
Subject: Audit requirements



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.



The first part of the confusion comes from the scope of the audit.

When engaging an auditor to provide attestion services, it is up to the 
organization to define the scope of the audit.  For audits utilizing the 
WebTrust criteria, the scope could be all parts of the criteria.  According to 
auditors I have spoken with, the report will indicate which portions of the 
criteria were in scope for the audit by including a statement of items in scope 
on the management assertion.

If the assertion does not include an item, or the auditor does not express an 
opinion about the item, then it should be assumed to be out of scope.



I have seen a number of reports that do not include all of the criteria be in 
scope.  Specifically, many reports do not provide an opinion on criteria 7 
("Subordinate CA Certificate Life Cycle

Management") of the Trust Services and Principles and Criteria for 
Certification Authorities.  Given the emphasis on subordinate CAs in the 
Mozilla policy, it would seem that this should be required for any CA which 
does not the zero path length constraint.  The current inclusion policy item 11 
presumably includes this already, but does not specifically state that all 
parts of the listed criteria must be included.



The second item of confusion seems to be which CA certificate subjects must be 
audited.  A number of CAs only include the subjects of CA certificates directly 
included in the Mozilla products and do not include the subjects of subordinate 
CA certificates.  My impression is that there should be a report clearly 
covering each of subject of a unconstrained CA certificate in the heirarchy, as 
described in item 8 of the inclusion policy.  This includes a Baseline 
Requirements report for any unconstrained CA, even if the CA is not intended to 
be used for server authentication ("SSL") certificates.



What is Mozilla's expectation?  Do CAs need to ensure that all components of 
the criteria are included in their report and ensure that all unconstrained 
subordinates are identified as being covered by the reports?



Thanks,

Peter

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