El viernes, 30 de marzo de 2018, 17:06:35 (UTC+2), Wayne Thayer  escribió:
> On Wed, Mar 28, 2018 at 3:45 AM, ramirommunoz--- via dev-security-policy <
> [email protected]> wrote:
> 
> >
> > On Tuesday, March 27, 2018 at 10:37:07 PM UTC+2, Wayne Thayer wrote:
> > > Hi Ramiro,
> > >
> > > On Fri, Mar 23, 2018 at 11:52 AM, ramirommunoz--- via
> > dev-security-policy <
> > > [email protected]> wrote:
> > >
> > > > Hi Ryan
> > > >
> > > > Thanks again for your remarks.
> > > > In the end I am going to learn something of PKI :-).
> > > > Surely I do not get a full understanding of you solution, but public
> > > > administration is requiring a EU qualified Web certificate this means
> > that
> > > > should be included in the EUTL. I do know other solution for a new
> > root but
> > > > a new conformity assessment.
> > > >
> > > > If the "2016" roots are included in the EUTL, then they can be used to
> > > sign ("cross-sign") a new "2018" root (or roots) that will then inherit
> > the
> > > trust from the "2016" root. From the perspective of the EUTL, the new
> > root
> > > would look like a new intermediate CA certificate.
> >
> > Wayne, the EUTL do not include ROOTS, only SubCA. It doesn't works in this
> > way. Our hypothetical new 2018 root should issue a SubCA for WEBSITE
> > certificates and this SubCA should be included in the EUTL, previously we
> > should pass a new conformity assessment and send it to our National
> > Supervisor body..and so on.
> >
> > In that case, the new "2018" root(s) could be used to cross-sign the older
> roots to provide a transition that allows your "2016" roots to be trusted
> in Mozilla products until the "2018" SubCAs are added to the EUTL.
> 
> > >
> > > Nevertheless, let me insist. In which aspects a new root 2018 improve our
> > > > trustworthiness instead of the current root 2016?
> > > >
> > > > This is the wrong question to ask. For all the reasons stated in
> > earlier
> > > messages, the Mozilla community appears to have concluded that the 2016
> > > roots are not trustworthy. If that is the case, then the proposal that
> > you
> > > create a new root answers the question that I think you should be asking:
> > > "How can Camerfirma regain the community's trust?" Submitting a new root
> > > that has been audited, has no history of misissuance, and complies in
> > every
> > > way with our policies has been proposed as one possible way to increase
> > > confidence in your CA. If you have been following this mailing list, you
> > > have seen that this same action has been recommended to other CAs that
> > are
> > > in this situation.
> > >
> >
> > Wayne, all issues stated are already resolved, Moreover actually 2016 root
> > is not affected by those problems. That's why I do not see the difference
> > between 2016 root and a new 2018 root.
> >
> > Documented misissuance from the 2016 roots:
> https://crt.sh/?caid=50473&opt=cablint,zlint,x509lint&minNotBefore=2011-01-01
> 
> Moreover, all of the CPS issues that I identified apply to the 2016 roots,
> and many of the other issues - such as CAA failures - apply equally to
> these roots. So why do you believe that the '2016 root is not affected by
> those problems'?
> 
> Nevertheless We offer a "Point in time audit" over 2016 root in order to
> > provide to the community a clear assurance that all technical controls are
> > in place and fulfill the BR requirements. Previously, to start from a clean
> > point, We offer as well to revoke all WebSite certificates issued under
> > this root.
> >
> > We think that this proposal should provide a similar situation that we
> > would have if a new 2018 root were set up.
> >
> > Regards
> > Ramiro
> >
> >
Hi Wayne
Thank you again for your answer

I fully understand the proposed solution about 2018 roots but as I previously 
said some concerns arise, not only for timing issues, but also from unexpected 
behaviours in some environment (EUTL, Spanish Public Administration validation 
platforms...etc) that could have a significant impact in our certificate 
distribution, so if we can we would like to avoid this solution.

What about Camerfirma proposal:

1.- A complete revocation of any SSL certificate issued by 2016 root
2.- "Point in time" BR audit
3.- Start issuing certificates from a clean environment from 2016 root

This would be a quicker and good solution for us and we think this guarantee 
the community that everything is corrected and ok from this point on.

Best Regards
Ramiro

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