On Mon, Mar 26, 2018 at 3:06 PM, Wayne Thayer via dev-security-policy < [email protected]> wrote:
> Mozilla began requiring BR audits for roots in our program in 2013 [1], but > we have a vague policy statement in section 3.1 regarding audit > requirements prior to inclusion: > > Before being included and periodically thereafter, CAs MUST obtain certain > > audits… > > > > BR section 8.1 contains the following paragraph: > > If the CA does not have a currently valid Audit Report indicating > > compliance with one of the audit schemes listed in Section 8.1, then, > > before issuing Publicly-Trusted Certificates, the CA SHALL successfully > > complete a point-in-time readiness assessment performed in accordance > with > > applicable standards under one of the audit schemes listed in Section > 8.1. > > The point-in-time readiness assessment SHALL be completed no earlier than > > twelve (12) months prior to issuing Publicly-Trusted Certificates and > SHALL > > be followed by a complete audit under such scheme within ninety (90) days > > of issuing the first Publicly-Trusted Certificate. > > > > Unfortunately, the definition of Publicly-Trusted Certificates exempts > newly created roots from this requirement, and in practice we have seen > that violating this requirement does not prevent roots from receiving BR > audit statements. We continue to see inclusion requests for roots that do > not have an unbroken chain of BR audits back to first issuance. > > I propose that we add a requirement to Mozilla policy section 3.1.3 for > roots to have contiguous audits beginning within 90 days of issuing the > first certificate. I chose 90 days to allow some time for issuing > subordinate CA certificates and test certificates in preparation for the > audit. > . > This is: https://github.com/mozilla/pkipolicy/issues/113 > > [1] https://wiki.mozilla.org/CA:CertificatePolicyV2.1#Audit_Criteria > [2] > https://groups.google.com/d/msg/mozilla.dev.security.policy/Mezqdljjerc/ > nIirftRqAgAJ I'm not fully sure I understand the proposal here. I would think that, for all roots created since 2012, the expectation is that there is an unbroken series of audits, going from a Point in Time audit (of the policies and infrastructure) to a Root Key Generation Ceremony attestation (under the policies and practices) to a Period of Time audit, with the issuance of any supporting infrastructure appearing between the RKGC and the PoT and covered by the PoT audit. Does that match your intent? Assuming I did not botch the audit timing issues here _______________________________________________ dev-security-policy mailing list [email protected] https://lists.mozilla.org/listinfo/dev-security-policy
