On 21/06/17 16:58, Doug Beattie wrote:
>> It's worth noting that if we had discovered this situation for SSL - that an
>> unconstrained intermediate or uncontrolled power of issuance had been
>> given to a company with no audit - we would be requiring the intermediate
>> be revoked today, and probably taking further action as well.
> 
> Agree

After consultation, I have decided to implement this requirement with a
phase-in period of six months, for already-existing intermediates. So
before 15th January 2018 (add a bit because of Christmas) these
customers, and any others like them at any other CA, need to have audits
(over at least 30 days of operations), move to a name-constrained
intermediate, or move to a managed service which does domain ownership
validation on each domain added to the system. I expect these two
intermediates to be revoked on or before 15th January 2018.

I realise this is not what you were hoping for, but it's not reasonable
to leave unconstrained intermediates in the hands of those not qualified
to hold them for a further 2 years. I am allowing six months because,
despite the weakness of the previous controls, you were in compliance
with them and so it's not reasonable to ask for a super-quick move.

https://github.com/mozilla/pkipolicy/commit/44ae763f24d6509bb2311d33950108ec5ec87082

(ignore the erroneously-added logfile).

> Are there any other CAs or mail vendors that have tested name constrained 
> issuing CAs? If using name constrained CAs don’t work with some or all of the 
> mail applications, it seems like we might as well recommend a change to the 
> requirement.

I am open to hearing further evidence on this point.

Gerv
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