On Tue, Oct 30, 2018 at 1:10 PM Erwann Abalea via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> In fact, for the Relying Party, these certificates are definitely
> considered as Qualified certificates for website authentication, regardless
> of the content of the QCStatement extension.
> Grab the German TL, find the T-Systems TSP, this specific service, you'll
> see it's declared as a CA/QC type, status granted, with a Sie equal to
> ForWebSiteAuthentication. There is no ambiguity (yet).
>

On what basis do you believe this claim is to be made? By virtue of
asserting qcStatement-1? If qcStatement was mis-encoded, or qcStatement-1
was absent, do you believe the same?

I'm not sure the ambiguity can be as easily resolved as you suggest, given
the description within EN 319 412-5


> Are we going to also revoke all the certificates which contain encoded
> DEFAULT values (in the ASN.1 sense), invalid PrintableString attributes,
> invalid hostnames,


Yes. This has already been the process now for several years, as shown
through both https://wiki.mozilla.org/CA/Incident_Dashboard and the
https://wiki.mozilla.org/CA/Closed_Incidents

It is interesting that you chose those examples, as several are explicitly
called out in the Root Policy at
https://github.com/mozilla/pkipolicy/blob/master/rootstore/policy.md#52-forbidden-and-required-practices


> and reject audits performed by auditors who missed such certificates?
>

Yes. In general, the failure to detect such issues has called into question
the competency of the auditor, as has the failure to disclose such issues.
Both are relevant here, combined with the approach to revocation and
overall testing methodology. Further, as detailed, the misleading remarks
regarding what was examined are equally reason to question the competency
of the auditor.

This is no different than the rejection of audits from some
WebTrust-accredited practioners due to significant oversights about ongoing
and persistent misissuance that is critical within the scope of the audit
scheme being used. The failure to detect such issues fundamentally calls
into question the validity of the current audit, as well as those audits
performed for other CAs. The response of the auditor to such issues equally
bears calling into question the competencies of the auditor.


> This esi4-qcStatement-6 QCStatement is a recent addition, has been really
> poorly designed (a SEQUENCE OF that shall contain only 1 element, what a
> great idea), and has seen several changes during the draft. It's an easy
> statement, I agree, and a decent TSP shouldn't make any mistake in encoding
> it.
> But on the control side, there's not that much available tool to decode a
> QCStatements extension (and no, "openssl asn1parse" and "dumpasn1" don't
> count).
>

Considering that even prior versions (e.g. 2.0.12) included an ASN.1 module
as a normative inclusion (Annex B), I find this profoundly non-compelling.
See
https://www.etsi.org/deliver/etsi_en/319400_319499/31941205/02.01.01_60/en_31941205v020101p.pdf
.
As you dig through these versions, the adopted versions do not share the
ambiguity issues. You're correct that 2.2.0 formalized the corrigenda
against 2.2.1 to include, textually, the normative requirement of "one and
exactly one" method, but in either event, such encodings violate it
entirely.

I also fail to understand how one can argue that the CAB is following
industry best practice, considering that industry best practice has
included within it the use of tools such as certlint (which can ingest
ASN.1 modules) or zlint (for which compliance support can be included). In
any event, the testing procedure of visual inspection without actually
conforming against the grammar is a fundamental approach to audit
methodologies that does not stand up to scrutiny, and seriously calls into
question the core competencies.
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