On Wed, Jan 2, 2019 at 11:32 AM Jakob Bohm via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On 02/01/2019 17:17, Wayne Thayer wrote:
> > The options to consider are:
> > 1. Continue with current policy of treating non-disclosure of
> unconstrained
> > intermediates as an incident. This could eventually lead to having the
> > offending intermediate added to OneCRL, but in practice it never has
> > because disclosure is not difficult.
>
> No comment
>
> > 2. Change our policy to state that any undisclosed intermediate we
> discover
> > will be immediately and permanently added to OneCRL.
>
> This needs adding some logical criteria, notably:
>
> - Allow the SubCA certificate itself and any related technical
>   signatures (CRL, OCSP signer, test site signatures etc.) and deeper
>   SubSubCAs to be generated and added to CT as part of the signing
>   ceremony before submission.  This of cause within the reporting
>   deadline already specified in Mozilla policy for new SubCAs.
>
> - Send a stern warning e-mail to the CA contact when 2/3 of the time
>   between SubCA generation and deadline expiry has passed.
>
> How do we know about the SubCA if it hasn't been disclosed? By the time
the SubCA appears in CT, the 1-week disclosure deadline has very likely
passed.

- Include a manual review to check for misidentification of SubCA
>   submission policy violations (such as the Izenpe case earlier today).
>
> - An exception if there was a relevant CCADB issue (downtime,
>   configuration, account problems etc.) during the CCADB submission
>   deadline.
>
> - In OneCRL, add a separate OneCRL reason marker for SubCAs revoked in
>   for this reason only.  This to allow extremely space or bandwidth
>   constrained OneCRL consumers to omit those, as well as to provide
>   truthful error messages in full clients such as Firefox.
>
> > 3. Wait for the "intermediate preloading" feature to ship in Firefox. As
> > currently defined, this is not an enforcement mechanism for disclosure,
> but
> > it could be.
>
> Note however that there is always the issue that "intermediate
> preloading" will typically only update along the browser/mailclient
> /other software release schedule while SubCAs can be validly created and
> disclosed at any time (in practice: On the CAs root ceremony schedule).
>
> Intermediate preloading will use the same distribution mechanism as
OneCRL. Yes, there will be some delay before a new intermediate is known by
most/all clients, but the timescale is hours, not weeks.

> 4. Assume that CT enforcement will (eventually, on some undefined timeline
> > for Firefox) force intermediate disclosures and eliminate the need for
> > Mozilla to require CAs to manually disclose serverAuth intermediates in
> > CCADB.
> >
>
> CT disclosed SubCAs not in CCADB are the typical case of currently
> detected violations.  Thus CT enforcement would not fix this unless CT
> enforcement causes the CCADB disclosure rule to be removed/relaxed as
> redundant.
>
>
Yes, the idea is that CT could remove the need to enforce intermediate
disclosures via policy.

> I don't expect options 3 and 4 to be viable for S/MIME certificates
> anytime
> > soon, so different options might be chosen for TLS and S/MIME.
> >
> > I'm interested to hear if anyone has opinions on these options.
> >
>
>
> Enjoy
>
> Jakob
> --
> Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
> Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
> This public discussion message is non-binding and may contain errors.
> WiseMo - Remote Service Management for PCs, Phones and Embedded
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