Thanks Gerv.

Code signing certificates don't contain EKU of id-kp-serverAuth, 
id-kp-emailProtection so it's out of scope for the policy.  I didn't take the 
statement "key pairs for signer" and narrow that down to "S/MIME signing", now 
I get it.

For S/MIME you said the Problematic Practices page permits CAs to generate 
keys, but to be clear, it's only permitted for the Encryption certificates, and 
not for S/MIME signature certificates.  If you have one S/MIME cert for both 
signing and encryption then CAs must not generate the keys pairs.  Is that 
right?

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> [email protected]] On Behalf Of Gervase
> Markham via dev-security-policy
> Sent: Wednesday, November 22, 2017 10:57 AM
> To: [email protected]
> Subject: Re: Forbidden Practices: Subscriber key generation
> 
> On 14/11/17 21:53, Doug Beattie wrote
> > The question is, if we issue Code Signing certificates via P12 files
> > in compliance with the Code Signing standard, are we out of compliance
> > with the Mozilla policy?  How do you recommend we respond to this
> > checklist question?
> 
> Mozilla does not have policies relating to code signing. We would therefore
> expect CAs to arrange things such that their code signing activities fall 
> outside
> the scope of the Mozilla policy. The scope statement in the policy section 
> 1.1,
> and it seems to me that the easiest technical way to achieve this is to do 
> code
> signing activities under an intermediate which is technically constrained so 
> it
> cannot issue email or server certs.
> 
> > And the same for S/MIME and SSL certificates.  If CAs generate and
> > then securely distribute the keys to the subscribers using similar
> > methods, is that permitted provided we implement similar security, or
> > does that practice need to immediately stop?  Your guidance in this
> > area would be appreciated.
> 
> For SSL, I would say it needs to immediately stop. Although see:
> https://github.com/mozilla/pkipolicy/issues/107
> 
> For S/MIME, as you can see, the Problematic Practices page permits it.
>
> > Side question: Is there a deadline when you expect to receive
> > self-assessments from all CAs?  We've found that complying with the
> > checklist means a major update to our CPS (among other things...), and
> > I suspect most other CAs will also need a major update.
> 
> I believe Kathleen did put a date in the CA Communication. If you need more
> time, contact certificates@mozilla dot org with your good reasons :-)
> 
> Gerv
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