On Mon, Oct 7, 2019 at 7:06 PM Jeremy Rowley <jeremy.row...@digicert.com>

> Interesting. I can't tell with the Netlock certificate, but the other
> three non-EKU intermediates look like replacements for intermediates that
> were issued before the policy date and then reissued after the compliance
> date.  The industry has established that renewal and new issuance are
> identical (source?), but we know some CAs treat these as different
> instances.

Source: Literally every time a CA tries to use it as an excuse? :)

My question is how we move past “CAs provide excuses”, and at what point
the same excuses fall flat?

While that's not an excuse, I can see why a CA could have issues with a
> renewal compared to new issuance as changing the profile may break the
> underlying CA.

That was Quovadis’s explanation, although with no detail to support that it
would break something, simply that they don’t review the things they sign.
Yes, I’m frustrated that CAs continue to struggle with anything that is not
entirely supervised. What’s the point of trusting a CA then?

 However, there's probably something better than "trust" vs. "distrust" or
> "revoke" v "non-revoke", especially when it comes to an intermediate.  I
> guess the question is what is the primary goal for Mozilla? Protect users?
> Enforce compliance?  They are not mutually exclusive objectives of course,
> but the primary drive may influence how to treat issuing CA non-compliance
> vs. end-entity compliance.

I think a minimum goal is to ensure the CAs they trust are competent and
take their job seriously, fully aware of the risk they pose. I am more
concerned about issues like this which CAs like QuoVadis acknowledges they
would not cause.

The suggestion of a spectrum of responses fundamentally suggests root
stores should eat the risk caused by CAs flagrant violations. I want to
understand why browsers should continue to be left holding the bag, and why
every effort at compliance seems to fall on how much the browsers push.

Of the four, only Quovadis has responded to the incident with real
> information, and none of them have filed the required format or given
> sufficient information. Is it too early to say what happens before there is
> more information about what went wrong? Key ceremonies are, unfortunately,
> very manual beasts. You can automate a lot of it with scripting tools, but
> the process of taking a key out, performing a ceremony, and putting things
> a way is not automated due to the off-line root and FIPS 140-3
> requirements.

Yes, I think it’s appropriate to defer discussing what should happen to
these specific CAs. However, I don’t think it’s too early to begin to try
and understand why it continues to be so easy to find massive amounts of
misissuance, and why policies that are clearly communicated and require
affirmative consent is something CAs are still messing up. It suggests
trying to improve things by strengthening requirements isn’t helping as
much as needed, and perhaps more consistent distrusting is a better

In any event, having CAs share the challenges is how we do better.
Understanding how the CAs not affected prevent these issues is equally
important. We NEED CAs to be better here, so what’s the missing part about
why it’s working for some and failing for others?

I know it seems extreme to suggest to start distrusting CAs over this, but
every single time, it seems there’s a CA communication, affirmative
consent, and then failure. The most recent failure to disclose CAs is
equally disappointing and frustrating, and it’s not clear we have CAs
adequately prepared to comply with 2.7, no matter how much we try.
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