Having given this some more thought, I suggest the following changes:

* Forbid "no stipulation" altogether. While there are a few sections where
it would be convenient to use "No stipulation" (e.g. 4.2.3 Time to Process
Certificate Applications), I don't see a requirement for more descriptive
language to be much of a burden (e.g. 4.2.3 could simply state: "we process
applications in a commercially reasonable time but do not publish specific
SLAs"). In the case of a CP that delegates requirements to one or more
CPSs, it is also more informative to state "Refer to CPS section" than to
use "No stipulation". Finally, if we continue to allow "No stipulation", we
really won't know if a CA is aware of this discussion and is using the term
properly.

* Section 1.1 of the BRs describes the reason that some sections are left
blank:

In accordance with RFC 3647 and to facilitate a comparison of other
certificate policies and CPSs (e.g. for policy mapping), this document
includes all sections of the RFC 3647 framework. However, rather than
beginning with a “no stipulation” comment in all empty sections, the
CA/Browser Forum is leaving such sections initially blank until a decision
of “no stipulation” is made.
Some of the blank sections also cover important information (e.g. 3.3.1
Identification and Authentication for Routine Re-key). We shouldn't allow
"No stipulation" for these either.

* Add a requirement that language that only applies to certificates that
are out-of-scope for Mozilla policy must be clearly marked as such. Many
CP/CPSs cover document signing and other certificate usages, but they often
aren't explicit about policies that aren't permitted for TLS and/or email
certificates. For example, it's permissible for a CP/CPS to describe
procedures for certificate suspension in 4.9.15, but it should clearly
state that suspension will not be used with TLS certificates.

* Finally, I think we need some effective date for these as required
practices. One approach would be to require compliance for any CP/CPS dated
after Dec 31, 2018.

- Wayne

On Tue, Oct 23, 2018 at 2:25 AM Kathleen Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> I have updated the section as follows:
> - Removed the sentence that was trying to limit the use of "No
> Stipulation". Hopefully the clarification about what these words mean is
> sufficient.
> - Added bullet points
> - Added "Sections MUST not be left blank. ..."
>
>
> https://wiki.mozilla.org/CA/Required_or_Recommended_Practices#CP.2FCPS_Structured_According_to_RFC_3647
>
>
> I continue to appreciate your feedback on this new section.
>
> Thanks,
> Kathleen
>
>
> _______________________________________________
> dev-security-policy mailing list
> dev-security-policy@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
>
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