Hey Matt,

Sorry this e-mail went unanswered. I was updating my mail filters today and
noticed it had been missed.

On Thu, May 7, 2020 at 8:03 AM Matt Palmer via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> This has happened twice now, with two different CAs, so I'm going to raise
> it as a general issue.
>
> I've had one CA reject e-mails because the HELO name wasn't to their liking
> (which I was able to fix).  The other, which has just started happening
> now,
> is utterly inscrutible -- "550 Administrative prohibition - envelope
> blocked".  Given that the envelope sender and recipient hasn't changed from
> the numerous other problem reports I've sent over the past month or so, I'm
> really at a loss as to how to proceed.
>
> Questions that arise in my mind:
>
> 1. To what extent is it reasonable for a CA to reject properly-formed
> e-mails to the CPS-published e-mail address for certificate problem
> reporting?
>

I don't know if I have a good answer for this. I think from your own
reporting, we've now seen a variety of responses from CAs - e.g. "antivirus
that prevents e-mailing CSRs" is still a ... rather surprising behaviour
that I don't know we've got a good hard-and-fast rule for.

As you know, to date, Mozilla has so far declined to make e-mail reporting
mandatory for CAs to support, precisely because of the complexities of
specifying a policy that is loophole free. At the same time, we're seeing a
telling trend of CAs restricting submissions for certain problem reports to
only particular mechanisms, and I think that's equally troubling: CAs are
placing barriers for reporters that, I believe, straddle the border if not
outright cross it of unreasonable burden.

Which I guess is to say "we'll take it on a case by case basis", and look
for opportunities for improved policies based on the hurdles that problem
reporters face.


> 2. What is a reasonable response from a problem reporter to a rejected
> problem report e-mail?
>

I would say bringing it here and/or in a CA incident.

Ultimately, both Root Program policies and the Baseline Requirements
themselves are improved based on experience and challenges faced. Knowing
the challenges faced by a problem reporter help us improve the policies.


> 3. In what ways are the required timelines for revocation impacted by the
> rejection of a properly-formed certificate problem report?
>

This is part of the challenge here. If we applied the logic a number of CAs
did during the CA/Browser Forum voting discussions (which lead to Bylaws
reform), we know that several CAs view the act of contacting a mail server,
even if it does not accept the message, as sufficient notification. Of
course, by Bylaws were clarified to take a less extreme position, of
confirmed receipt/acceptance.

I would say the answer is that this is case-by-case. CAs that place
burdensome barriers to receive reports of key compromise and/or
misissuance are, unquestionably, not acting in the public interest.
However, there are legitimate challenges. I think the best answer is
treating these as incident reports, and allowing the CA to provide their
explanation and rationale, and either treating it as a BR-violation
incident or closing as WontFix/Invalid, depending on the depth and quality
of the CA's report and the steps they take in response.
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