Thanks, Nick, for the comment on the scope difference in the dnsName 
constraints vs. SAN wildcard.  I hadn't contemplated that.  As you note, the 
real risk isn't dissimilar.  (I would presume that this is because a CA willing 
to issue a SAN dnsName of *.example.com would also presumably issue a SAN 
dnsName of *.research.example.com.)

Having given further consideration to potential exposures and risks of 
certificates issued downline of the name constrained intermediate, I did come 
up with one metric in which the risk profile _could_ be different versus a 
wildcard EE cert: the wildcard EE certs issued by a CA in the normal course of 
business must comply with the BRs pertaining to length of validity of 
validation information and maximum length of validity period of EE certificate 
life (and, of course, with the rest of the BRs).  It's not clear that such a 
standard or requirement would presently apply to a name constrained technically 
constrained intermediate certificate.

Perhaps it makes sense to only accord preferential treatment of name + eku 
constrained intermediates which are also constrained to limited period of 
validity.  Perhaps that constraint should mirror or only slightly exceed the 
limits on EE certs.

Out of curiosity, I checked crt.sh's CA certificates disclosure report to see 
if I could find an in-the-wild name constrained intermediate that I think 
largely reflects the overall attributes/constraints which might allow for 
preferential treatment, and found one for Southern Company (an energy & telecom 
company in the southeast USA).  The intermediate certificate in question is at: 
 https://crt.sh/?id=11501550

Southern Company seems to use this certificate to issue some of the EE 
certificates on some of their public facing websites.  https://southernlinc.com 
features a leaf certificate issued from this technically constrained 
intermediate.

Features, in particular, that I think may allow for preferential treatment of 
these intermediates, as demonstrated in the crt.sh linked intermediate above, 
include:

1.  Pathlen constraint in this example was 0, but I would presume a pathlen 1 
for policy CAs to allow for separate internal intermediates might be allowable 
too.  Not sure if allowing that adds a further risk exposure or not?  The 
effective eku applied to the EE certificate is the most restrictive eku of the 
certificates in the chain including the leaf certificate, right?  (Thus, 
declaring the further intermediate to have lesser / different name constraints 
or extra eku permissions would not be effective, correct?)
2.  The eku values here are constrained to TLS Server Auth, TLS Client Auth, 
Email Protection, and OCSP signing
3.  As email protection eku is selected, at least one permitted rfc822 name 
constraint exists.  Here, there are actually two: .sourthernco.com and 
southernco.com (presumably to allow issuance of email certs covering anything 
in the southernco.com namespace.
4.  As TLS server auth eku is present, name constraint exclusions for the whole 
IPv4 and IPv6 IP space are present.  Additionally, a number of permitted 
dnsName constraints are provided, listing out domains over which the validated 
organization has control.

In contemplating the risk of such intermediates spefically to the Web PKI, the 
only risks that I can presently imagine to exceed that of wildcard EE 
certificates thus pertain to validity period.  The example certificate I found 
has a 5 year validity period.

It seems to me, however, that while I am aware that one could cause the 
constrained intermediate to sign a certificate which is NOT baseline 
requirements compliant, modern Web PKI software would not honor this.  With the 
exception of that caveat, it would appear that proper name constraints, 
validity period, ekus, and path length constraints can combine to effectively 
force subordinate leaf certificates into alignment with the baseline 
requirements.  Thus, it would seem that disclosure of certificates descending 
from such intermediates is likely unnecessary.

As long as the validation and issuance of such constrained intermediates is 
watched by an externally audit-able mechanism like CT, I don't think these 
intermediates themselves would need specific disclosure in CCADB.

Thanks,

Matt
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