On Fri, Sep 7, 2018 at 9:55 AM Bruce via dev-security-policy <
[email protected]> wrote:

> On Thursday, September 6, 2018 at 7:44:15 PM UTC-4, Wayne Thayer wrote:
> > All,
> >
> > I've drafted a new email and survey that I hope to send to all CAs in the
> > Mozilla program next week. it focuses on compliance with the new (2.6.1)
> > version of our Root Store Policy. I would appreciate your feedback on the
> > draft:
> >
> >
> https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J00003rMGLL
> > <
> https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J00003mogw7
> >
> >
> > Thanks,
> >
> > Wayne
>
> With regard to the actions.
>
> ACTION 6 - Can we select CA certificates which we do not want pre-loaded?
> In some cases the CA certificate is no longer used and does not need
> pre-loading.
>
> ACTION 7 - Although we support the Chrome CT requirement, we do have a
> process to allow customers to choose not to CT log their certain SSL
> certificates. We do not redact names, but I suppose we allow a customer to
> redact certificates. As such, I don't think the responses listed in action
> 7 covers this model.
>

Correct. Chrome does not require 100% disclosure of certificates - however,
it does not trust undisclosed certificates. However, as Certificate
Transparency (RFC 6962) also supports non-embedding methods - such as TLS
or OCSP - it should also not be presumed that disclosure occurs at the time
of issuance. In particular, a site operator may choose not to have the CA
embed SCTs through the disclosure of precertificates, and instead disclose
them at a time prior to making those certificates operational. As a
concrete example, Google does this for some of its certificates.

If Mozilla is pursuing a 100% disclosure rule, while permitting
non-preloaded intermediates, then it seems this suggests that Mozilla's
desired configuration is that customers that opt-out of disclosure are done
so via a dedicated intermediate.

That is, one can imagine you, today, have
Root
Intermediate
(Disclosed Leaf) (Disclosed Leaf) (Non-Disclosed Leaf)

In a model "tomorrow", you would have
Root
Standard Intermediate
(Disclosed Leaf) (Disclosed Leaf)

Private Intermediate
(Non-Disclosed Leaf)

That is, the choice of a customer to not affirmatively disclose would seem
to necessitate dedicated hierarchy in order to meet Mozilla's objectives.
Wayne, is that the intent? Is there a phase-in time for CAs to establish
such a hierarchy?
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