The BRs define Repository as:

Repository: An online database containing publicly-disclosed PKI governance
documents (such as Certificate Policies and Certification Practice
Statements) and Certificate status information, either in the form of a CRL
or an OCSP response.

I see no evidence to support the idea that the scope of the term Repository
in section 4.9.13 is limited to issuing CAs. Therefore, a strict reading of
the BRs is that any BR-compliant root must not suspend any intermediate or
end-entity certificate in the hierarchy. I can understand how this causes
problems for CAs that rely on certificate suspension outside of TLS, and I
have not been enforcing this strict interpretation, but I do think the BRs
should be updated to solve this problem.

- Wayne

On Mon, Feb 4, 2019 at 10:07 AM Pedro Fuentes via dev-security-policy <
[email protected]> wrote:

> Well... my understanding is that “Repository” refers there to the one of
> the Issuing CA, not the whole repository under a Root, because a Root could
> have subordinates that don’t issue SSL, and for which suspension could be
> allowed.
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