This request is to enable EV treatment for the DigiCert Assured ID Root CA
and DigiCert Global Root CA as documented in the following bug:
https://bugzilla.mozilla.org/show_bug.cgi?id=1165472

* BR Self Assessment is here:
https://bug1165472.bmoattachments.org/attachment.cgi?id=8960346

* Summary of Information Gathered and Verified:
https://bug1165472.bmoattachments.org/attachment.cgi?id=8987141

* Root Certificate Download URLs:
** Global: https://www.digicert.com/CACerts/DigiCertGlobalRootCA.crt
** Assured: https://www.digicert.com/CACerts/DigiCertAssuredIDRootCA.crt

* CP/CPS:
** CP:
https://www.digicert.com/wp-content/uploads/2018/08/DigiCert_CP_v416.pdf
** CPS:
https://www.digicert.com/wp-content/uploads/2018/08/DigiCert_CPS_v416.pdf

* These roots are already included with Websites and Email trust bits. EV
treatment is requested.
** EV Policy OID: 2.23.140.1.1
** Original inclusion request:
https://bugzilla.mozilla.org/show_bug.cgi?id=364568

* Test Websites:
** Global:
*** Valid: https://global-root-ca.chain-demos.digicert.com/
***Expired: https://global-root-ca-expired.chain-demos.digicert.com/
*** Revoked: https://global-root-ca-revoked.chain-demos.digicert.com/
** Assured:
*** Valid: https://assured-id-root-ca.chain-demos.digicert.com/
***Expired: https://assured-id-root-ca-expired.chain-demos.digicert.com/
*** Revoked: https://assured-id-root-ca-revoked.chain-demos.digicert.com/

* CRL URLs:
** Global: http://crl3.digicert.com/DigiCertGlobalRootCA.crl and
http://crl4.digicert.com/DigiCertGlobalRootCA.crl
** Assured: http://crl3.digicert.com/DigiCertAssuredIDRootCA.crl and
http://crl4.digicert.com/DigiCertAssuredIDRootCA.crl

* OCSP URL: http://ocsp.digicert.com/

* Audit: Annual audits are performed by Scott S Perry, CPA according to the
WebTrust for CA, BR, and EV audit criteria.
** WebTrust: https://cert.webtrust.org/ViewSeal?id=2452
** BR: https://www.cpacanada.ca/webtrustseal?sealid=2453
** EV: https://www.cpacanada.ca/webtrustseal?sealid=2454

Additionally, DigiCert is undergoing quarterly audits (due to the Symantec
acquisition) that include the DigiCert Global Root CA and has been posting
the reports [1].


I’ve reviewed the CPS, BR Self Assessment, and related information for the
DigiCert Assured ID Root CA and DigiCert Global Root CA request that is
being tracked in this bug and have the following comments:

==Good==
* Other than my two comments below, the CP and CPS are in good shape and
they are well written and regularly updated.

==Meh==
* These are old roots, created in 2006, however, DigiCert has provided a
continuous chain of audits back to their creation [1]
* CPS section 3.2.2 permitted DigiCert to use vulnerable BR domain
validation methods 3.2.2.4.9 and 3.2.2.4.10. They are described as
deprecated in the latest version.
* DigiCert has had quite a number of compliance bugs over the past 18
months [2]. All but one is resolved (that one is awaiting the subordinate
CA to move to a managed PKI), DigiCert is generally responsive, and they
have self-reported a number of these issues.

==Bad==
* DigiCert’s most recent quarterly audit report states “During our
examination, we noted DigiCert publicly reported (
https://bugzilla.mozilla.org/show_bug.cgi?id=1483715) that it continued to
rely on a deprecated method of domain validation when renewing certificates
after the stated transition date of August 1, 2018. As a result, DigiCert
had to revalidate all affected 1233 certificates over 154 domains.“ At
least one of the certificates the required revalidation chains to the
DigiCert Global Root CA.
* The TERENA SSL CA 3 subordinate has misissued a number of certificates
[3], most of which are not revoked. DigiCert’s response in this bug states
“We were under the impression from previous communications with Mozilla
that certain types of errors identified did not require certificate
revocation. It would help if Mozilla could indicate which certificate
errors are believed to require revocation. We will then review the lists to
see which certificates need to be revoked.” I do not believe that Mozilla
should create such a list, and we have set a precedent for requiring
revocation for at least some of the errors that are identified - e.g.
metadata in subject fields [4].
* In addition, DigiCert previously reported that they had addressed the
problem of metadata in subject fields for certificates issued by the Terena
subordinate [5].
* Linters identify a large number of misissued certificates under the
DigiCert SHA2 Secure Server CA intermediate [6]. Many of these are false
positives (e.g. ZLint expects CN and SAN fields to be lowercased), but some
are not and of those many are not revoked - e.g. [7].
* CPS section 3.2.2 did not, in my opinion, adequately specify the
procedures employed to perform email address verification as required by
Mozilla policy section 2.2(2). The latest update addressed this.

This begins the 3-week comment period for this request [8].

I will greatly appreciate your thoughtful and constructive feedback on the
decision to grant EV treatment to these root certificates.

- Wayne

[1] https://bugzilla.mozilla.org/show_bug.cgi?id=1458024
[2]
https://bugzilla.mozilla.org/buglist.cgi?f1=creation_ts&list_id=14436306&short_desc=digicert&o1=greaterthan&resolution=---&resolution=FIXED&resolution=INVALID&resolution=WONTFIX&resolution=INACTIVE&resolution=DUPLICATE&resolution=WORKSFORME&resolution=INCOMPLETE&resolution=SUPPORT&resolution=EXPIRED&resolution=MOVED&query_format=advanced&short_desc_type=allwordssubstr&v1=2017-09-01&component=CA%20Certificate%20Compliance
[3]
https://crt.sh/?caid=1687&opt=cablint,zlint,x509lint&minNotBefore=2017-01-01
[4] https://crt.sh/?id=629259396&opt=cablint
[5] https://bugzilla.mozilla.org/show_bug.cgi?id=1397958
[6]
https://crt.sh/?caid=1191&opt=cablint,zlint,x509lint&minNotBefore=2017-01-01
[7] https://crt.sh/?id=286404787&opt=zlint
[8] https://wiki.mozilla.org/CA/Application_Process
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