On Monday, October 9, 2017 at 7:57:31 PM UTC+1, Kathleen Wilson wrote: > Here's what is currently in the bug... > https://bugzilla.mozilla.org/show_bug.cgi?id=1405862 > ~~ > As per Bug #1403549 the PSCProcert certificate will be removed from Mozilla’s > Root Store due to a long list of problems and the way that PROCERT responded > to those problems (and to previous CA Communications). For details about the > problems, see Bug #1391058 and https://wiki.mozilla.org/CA:PROCERT_Issues > > The purpose of this bug is to record the action items that PROCERT must > complete before their certificate may be included as a trust anchor in > Mozilla’s Root Store again. > > PROCERT may apply for inclusion of a new certificate[1] following Mozilla's > normal root inclusion/change process[2], after they have completed all of the > following action items. > > 1. Provide a list of changes that the CA plans to implement to ensure that > there are no future violations of Mozilla's CA Certificate Policy and the > CA/Browser Forum's Baseline Requirements. The list must be provided in this > bug, and accepted by Mozilla as reasonable remediation. > > 2. Implement the changes, and update their CP/CPS to fully document their > improved processes. > > 3. Provide a reasonably detailed[4] public-facing attestation from a licensed > auditor[3] acceptable to Mozilla that the changes have been made. This audit > may be part of an annual audit. > > 4. Provide auditor[3] attestation that a full performance audit has been > performed confirming compliance with the CA/Browser Forum's Baseline > Requirements. This audit may be part of an annual audit. > > > Notes: > [1] The new certificate (trust anchor) may be cross-signed by the removed > certificate. However, the removed certificate may *not* be cross-signed by > the new certificate, because that would bring the concerns about the removed > certificate into the scope of the new trust anchor. > [2] Mozilla's root inclusion/change process includes checking that > certificates in the CA hierarchy comply with the CA/Browser Forum's Baseline > Requirements. > [3] The auditor must be an external company, and approved by Mozilla. > [4] “detailed” audit report means that management attests to their system > design and the controls they have in place to ensure compliance, and the > auditor evaluates and attests to those controls. This assertion by management > - and the auditor's independent assessment of the factual veracity of that > assertion - will help provide a greater level of assurance that PROCERT has > successfully understood and integrated the BRs. > ~~ > > I could add a comment to the bug saying: > ~~ > To be clear… > > - This PSCProcert certificate will be removed, and the CA has to re-apply for > inclusion of the new certificate through Mozilla’s application process as > described here: > https://wiki.mozilla.org/CA/Application_Process#Process_Overview > However, the CA must not re-apply until all of the listed actions have been > completed, related documents provided in this bug, and resulting > documents/audits approved by Mozilla in this bug. > > - Action #3 must not start until Action #1 and Action #2 are done, and the > resulting documents approved by Mozilla in this bug. > > - As with all root inclusion applications, the new CA hierarchy, processes, > issued certificates, CP/CPS, BR Self Assessment, and audits must fully comply > with Mozilla’s Root Store Policy and the CA/Browser Forum’s Baseline > requirements. Otherwise, there will be further delay. > ~~ > > Does that make it clear enough that this is not something to be rushed? > And that the items each need to be approved by Mozilla in the bug? > > I'm not fond of the idea of stating time delays up front, when our > application process is by-design very slow and cumbersome already. (Just ask > the CAs who have been waiting for over a year for the discussion of their > root inclusion/update requests to start.) > > I think the "get it right or face delay" concept is already a standard part > of our application process. > > Action #3 already requires an audit statement about the changes. > > I'm not comfortable with the idea of having an auditor report to Mozilla and > not the applicant, because I would suspect that might require some > contractual agreements and/or NDAs, and I do not sign contractual agreements > or NDAs with CAs. > > Thanks, > Kathleen
Hi Kathleen, I think there be a comment relating to whether PROCERT is allowed/disallowed to cross-sign their new root CA with another CA. James _______________________________________________ dev-security-policy mailing list [email protected] https://lists.mozilla.org/listinfo/dev-security-policy

