Kathleen and Pedro,

Thank you for raising these legitimate concerns. I continue to believe that
a literal reading of the current requirement is that it already does apply
to S/MIME certificates, and the discussion I mentioned supports that
interpretation.

I propose two new options to solve this problem:
* Remove S/MIME certificates from the scope of section 6 and wait for the
CAB Forum to publish baseline requirements for S/MIME. I suspect that is a
few years away given that the working group is still in the process of
being chartered. However, this option is consistent with some people's
interpretation of the existing requirements.
* Add a subsection on revocation specific to S/MIME certificates and
populate it with a version of the BR requirements tailored to S/MIME. We'd
probably need to include requirements for S/MIME Intermediates as well as
leaf certificates.

A third option would be to specify the parts of the BR revocation
requirements that don't apply to S/MIME certificates, but after reviewing
section 4.9.1, I think this would be confusing, at best.

I would appreciate everyone's input on the best way to address this issue.

- Wayne


On Fri, May 3, 2019 at 5:12 AM Pedro Fuentes via dev-security-policy <
[email protected]> wrote:

> Hello,
> my main concern about applying this would be that this would lead to
> forbid the option to suspend a personal certificate.
>
> On a side note about suspension... I was not active in the forums when
> this was discussed and adopted and I'm sure there was a clear benefit on
> disallowing suspensions, but it's kind of a hassle already because of the
> application of this rule to the whole hierarchy. We'd like for example to
> have the capability to suspend a subordinate CA that is under investigation
> or that is pending of an audit, but right now we can't do it... extending
> these rules to personal certificates is not something I'm personally too
> enthusiastic.
>
> Best,
> Pedro
>
> El jueves, 2 de mayo de 2019, 17:32:43 (UTC+2), Kathleen Wilson  escribió:
> > Just want to make it very clear to everyone, that the proposal, to add
> > the following text to section 6 of Mozilla's Root Store Policy would
> > mean that certs constrained to id-kp-emailProtection (end-entity and
> > intermediate), i.e. S/MIME certs, would be subject to the same BR rules
> > and revocation timelines as TLS/SSL certs.
> >
> > > This requirement applies to certificates that are not otherwise
> required
> > >> to comply with the BRs.
> >
> > For example, Section 4.9.1.1 of the BRs says:
> > ""
> > MUST revoke a Certificate within 5 days if one or more of the following
> > occurs: ...
> >
> > 1. The Certificate no longer complies with the requirements of Sections
> > 6.1.5 and 6.1.6;
> >      ...
> > 7. The CA is made aware that the Certificate was not issued in
> > accordance with these Requirements
> > ""
> >
> > I interpret "these Requirements" to mean the BRs. Therefore, my
> > interpretation of the proposed additional text is that certs that are
> > constrained to S/MIME would also have to be issued in full accordance
> > with the BRs and would have to be revoked within the timeline as
> > specified in the BRs when found to be not in full compliance with the BR
> > issuance rules.
> >
> > Section 1.1 of Mozilla's root store policy limits the scope of the
> > policy such that the proposed additional text would only specifically
> > add the rules to S/MIME certs. Certs with no EKU extension or
> > anyExtendedKeyUsage are considered technically capable of issuing TLS
> > certs, so already subject to the rules of the BRs.
> >
> > Therefore, my concern is that the proposed additional text would mean
> > that all of the BR issuance rules and revocation rules would also apply
> > to S/MIME certs. I do not think that S/MIME certs have been taken into
> > account in the BRs, so I do not think we should impose all the BR
> > issuance and revocation rules on S/MIME certs.
> >
> > Kathleen
> _______________________________________________
> dev-security-policy mailing list
> [email protected]
> https://lists.mozilla.org/listinfo/dev-security-policy
>
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  • Policy 2.7 Proposal: Clarif... Wayne Thayer via dev-security-policy
    • Re: Policy 2.7 Proposa... Wayne Thayer via dev-security-policy
      • Re: Policy 2.7 Pro... Kathleen Wilson via dev-security-policy
        • Re: Policy 2.7... Pedro Fuentes via dev-security-policy
          • Re: Policy... Wayne Thayer via dev-security-policy
            • RE: P... Jeremy Rowley via dev-security-policy
              • R... Wayne Thayer via dev-security-policy
                • ... Kathleen Wilson via dev-security-policy
                • ... Wayne Thayer via dev-security-policy
                • ... Dimitris Zacharopoulos via dev-security-policy
                • ... Wayne Thayer via dev-security-policy
                • ... Wayne Thayer via dev-security-policy
                • ... Wayne Thayer via dev-security-policy

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