On Friday, September 8, 2017 at 3:25:20 PM UTC-4, Andrew Ayer wrote:
> The BRs state:
> 
> "Effective as of 8 September 2017, section 4.2 of a CA's Certificate
> Policy and/or Certification Practice Statement (section 4.1 for CAs
> still conforming to RFC 2527) SHALL state the CA's policy or practice
> on processing CAA Records for Fully Qualified Domain Names; that policy
> shall be consistent with these Requirements. It shall clearly specify
> the set of Issuer Domain Names that the CA recognises in CAA 'issue' or
> 'issuewild' records as permitting it to issue. The CA SHALL log all
> actions taken, if any, consistent with its processing practice."
> 
> Since it is now 8 September 2017, I decided to spot check the CP/CPSes
> of some CAs.
> 
> At time of writing, the latest published CP/CPSes of the following CAs
> are not compliant with the above provision of the BRs:
> 
> Amazon (https://www.amazontrust.com/repository/) - Does not check CAA
> 
> Comodo (https://www.comodo.com/about/comodo-agreements.php) - Does not
> specify issuer domain names
> 
> DigiCert (https://www.digicert.com/legal-repository/) - Does not
> specify issuer domain names, and processing is not compliant with BRs
> ("If a CAA record exists that does not list DigiCert as an authorized
> CA, DigiCert verifies that the applicant has authorized issuance,
> despite the CAA record.")
> 
> Google Trust Services (https://pki.goog/) - Does not check CAA
> 
> Identrust (https://secure.identrust.com/certificates/policy/ts/) -
> Does not check CAA
> 
> Izenpe
> (http://www.izenpe.eus/s15-content/en/contenidos/informacion/descarga_certificados/es_url/index.shtml)
> - Does not specify issuer domain names
> 
> PROCERT (https://www.procert.net.ve/eng/ca.html) - No mention of CAA
> 
> Symantec / GeoTrust (https://www.geotrust.com/resources/repository/legal/)
> - Does not specify issuer domain names
> 
> Trustis (https://www.trustis.com/pki/trustis-ssl/standard/index.htm) -
> No mention of CAA
> 
> Visa (http://www.visa.com/pki/) - Does not check CAA
> 
> 
> These CAs have compliant CP/CPSes:
> 
> Entrust
> 
> GlobalSign
> 
> GoDaddy
> 
> Let's Encrypt
> 
> QuoVadis
> 
> Trustwave
> 
> 
> It would be nice to hear confirmation from the non-compliant CAs that they
> really are checking CAA as required, and if so, why they overlooked the
> requirement to update their CP/CPS.
> 
> Regards,
> Andrew


IdenTrust confirms CAA record check has been implemented for every SSL 
certificate prior to issuance, effective September 8, 2017.
We will post updated CPS as soon as possible. Currently it is under PMA review 
and approval.
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