Hello, Based on the updated documentation, I've compiled the following questions for clarification:
------------ CPS Section 1.4.2 states "Unless stated otherwise, in this document, “RA” covers the Registration Authority and Delegate Registration Authorities." CPS Section 3.2 calls out DRAs ability to perform initial identity validation steps and uses the phrasing “RA (RA or DRA)” at the beginning of the section. CPS Section 4.2.1 states that during the identification and request validation process, that a DRA forwards the steps undertaken (including validation of domain control), and the RA "ensures that the request corresponds to the mandate of the DRA operator" Due to the language in 1.4.2 stating that unless stated otherwise, “RA” refers to both Registration Authorities and Delegated Registration Authorities, can you direct me to where in the CP/CPS it calls out that DRAs, Certificate Managers, and Certificate Agents (as defined in Section 1.4.5) are specifically unable to perform the validation checks of 3.2.2.4 and 3.2.2.5? Additionally, what does it mean for an RA to “ensure that the request corresponds to the mandate of the DRA operator”? ------------ CPS Section 4.2.1: If the request is valid and allows to obtain with accuracy the authorization to issue the certificate by a legal representative of the entity which is owner of the domain names, the CA authorizes itself to issue the certificate even if the CA is not present in the list of authorized CA. This appears to directly contravene BR Section 3.2.2.8, which specifies the following 3 scenarios in which a CA can issue a certificate despite not appearing in the CAA record: • CAA checking is optional for certificates for which a Certificate Transparency pre-certificate was created and logged in at least two public logs, and for which CAA was checked. Forum Guideline Baseline Requirements, v. 1.6.0 21 • CAA checking is optional for certificates issued by a Technically Constrained Subordinate CA Certificate as set out in Baseline Requirements section 7.1.5, where the lack of CAA checking is an explicit contractual provision in the contract with the Applicant. • CAA checking is optional if the CA or an Affiliate of the CA is the DNS Operator (as defined in RFC 7719) of the domain's DNS. ------------ CPS Section 3.2.7 calls out special actions taken for “High Risk Certification Requests”. It says the procedures for determining high risk as well as additional vetting requirements are documented, however, I do not see this documentation anywhere. On what basis is a certification request deemed “high risk” and in what way, specifically, does this impact a subscriber’s ability to obtain a certificate? ------------ Root CA CP Section 4.3.2: The delivery of certificate is achieved during the key ceremony, to a CA administrator authorized by CA and in charge of its exploitation and diffusion. Can you please explain what these sentences mean? This sub-section is cited as the response to BR Section 4.3.1 CA Actions during Certificate Issuance in the latest version of the BR self-assessment, but does not appear to speak to this requirement. ------------ _______________________________________________ dev-security-policy mailing list [email protected] https://lists.mozilla.org/listinfo/dev-security-policy

