Yes, that date comes from the Mozilla Root Program, but this requirement is new 
for the other Root Programs and for the BR.

The other thing is that without having an indicated effect date, the 
requirement can be interpreted in that way, that every valid Subordinate CA 
certificate shall comply this requirement, even if it has been issued years ago.

I would just like to get  confirmation  that this requirement does not mean 
that all subordinate CA certificates that are currently non-compliant shall be 
revoked, which were issued prior to the effective date.

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