Perhaps the solution should be to amend the BRs to allow for more flexible 
handling of situations such as this.

I understand that'd be rather difficult to formalize, since we can't just trust 
the CAs to decide for themselves when mass revocation doesn't make sense (as 
they have a vested interest in not revoking), and security impact isn't 
something that's easy to objectively quantify. However, the current status quo 
where millions of certs need to be revoked due to a technicality that has 
practically no impact on actual security seems silly.

Remember that the security impact of revoking still-in-use certificates that do 
not  actually pose a security risk is negative, as it leads to warning  
fatigue. Users who frequently encounter warnings about revoked certificates are 
more likely to bypass those warnings in the future. Not to mention the negative 
impact on the CA system as a whole, with increased operating costs for CAs and 
customers alike resulting from the additional work required to replace 
certificates.

On Friday, March 15, 2019 at 12:11:40 AM UTC-5, Ryan Sleevi wrote:
> On Fri, Mar 15, 2019 at 12:36 AM Jaime Hablutzel via dev-security-policy <
> [email protected]> wrote:
> 
> > Could you please provide me a link to a previous discussion where the
> > negative was stated, maybe by the module owner?. But note that I'm not
> > asking for a bespoke or improvised exception for the current issue but for
> > the possibility to introduce a procedure to handle any type of low
> > breach/high disruption violations now and in the future?.
> >
> 
> "However, Mozilla does not grant exceptions to the BR revocation
> requirements." [1]
> "In my opinion, Mozilla should not get in to the business of granting
> one-off exceptions ..." [2]
> 
> [1] https://wiki.mozilla.org/CA/Responding_To_An_Incident
> [2]
> https://groups.google.com/d/msg/mozilla.dev.security.policy/S2KNbJSJ-hs/HNDX5LaZCAAJ
> (That's this thread, one week ago)
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