Last year we held a discussion on this topic [1] that concluded as follows:

It is true that in the case of a legacy root, creating a new root with a
> cross-sign is not technically all that complex (although it may take
> some time organizationally) and then we could embed that new one.
>
> Given that option, perhaps a blanket statement of BR compliance for all
> unexpired and unrevoked certificates is OK - allowing the CA to choose
> how best to meet the requirement.
>

I believe that the solution I proposed for issue 113 [2] (Require audits
back to first issuance) also takes care of this issue. Here is what I
proposed:

In section 2.3 (Baseline Requirements Conformance), add a new bullet that
> states "Before being included, CAs MUST provide evidence that their root
> certificates have, from the time of creation and continually thereafter,
> complied with the then current Mozilla Root Store Policy and CA/Browser
> Forum Baseline Requirements."
>

Once again, I'd appreciate everyone's input on this topic.

This is: https://github.com/mozilla/pkipolicy/issues/99

[1]
https://groups.google.com/forum/#!topic/mozilla.dev.security.policy/2vBlRyfwxEs
[2]
https://groups.google.com/d/msg/mozilla.dev.security.policy/rR9g5BJ6R8E/TPgol2fcBwAJ

-------

This is a proposed update to Mozilla's root store policy for version
2.6. Please keep discussion in this group rather than on GitHub. Silence
is consent.

Policy 2.5 (current version):
https://github.com/mozilla/pkipolicy/blob/2.5/rootstore/policy.md
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