Hello,

Based on the updated documentation, I've compiled the following questions for 
clarification:

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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”? 

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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.

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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?

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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.

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