Agreed, I'd support a requirement that mandated revocation of a certificate 
using the domain validation processes supported by the CA in issuance. If you 
can prove control enough to get a certificate from the CA, then you are able 
to prove control enough to revoke a certificate.

-----Original Message-----
From: Tom Ritter [mailto:[email protected]]
Sent: Wednesday, November 2, 2016 10:45 AM
To: Jeremy Rowley <[email protected]>
Cc: Peter Bowen <[email protected]>; 
[email protected]; Jakob Bohm 
<[email protected]>
Subject: Re: Cerificate Concern about Cloudflare's DNS

On 2 November 2016 at 11:24, Jeremy Rowley <[email protected]> wrote:
> Revocation support for non-subscribers is sort of implied...sort of:
>
> Section 4.9.3:
> The CA SHALL provide Subscribers, Relying Parties, Application
> Software Suppliers, and other third parties with clear instructions
> for reporting suspected Private Key Compromise, Certificate misuse, or
> other types of fraud, compromise, misuse, inappropriate conduct, or any 
> other matter related to Certificates. The CA SHALL publicly disclose the 
> instructions through a readily accessible online means.
>

This was the text I was imagining being triggered by this scenario.

I certainly accept the fact that a CA has a reasonable reason to doubt random 
incoming "Please revoke this certificate" requests, and could or should 
require additional verification before taking action. I would imagine that for 
DV revocations, such verification would be pretty much identical to DV 
verification. The hard part is merely automating the process for scale like 
they do for DV issuance. (But if a CA got enough of these requests it could 
save some engineering by reusing that verification infrastructure!)

-tom

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