> I also read this language:
> If a CRL entry is for a Certificate not subject to these Requirements and was 
> either issued on-or-after 2020-09-30 or has a notBefore on-or-after 
> 2020-09-30, the CRLReason MUST NOT be certificateHold (6).

I think "was either issued on-or-after 2020-09-30 or has a notBefore 
on-or-after 2020-09-30" is talking about "a Certificate not subject to these 
Requirements", not about when the CRL was issued.

________________________________
From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> on 
behalf of Jeremy Rowley via dev-security-policy 
<dev-security-policy@lists.mozilla.org>
Sent: 30 September 2020 17:41
To: Mozilla <mozilla-dev-security-pol...@lists.mozilla.org>
Subject: RE: Mandatory reasonCode analysis

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This is a good question. I read the requirements as applying only to CRLs and 
OCSP published after the effective date since the BRs always say explicitly 
when they apply to items before the effective date.

I also read this language:
If a CRL entry is for a Certificate not subject to these Requirements and was 
either issued on-or-after 2020-09-30 or has a notBefore on-or-after 2020-09-30, 
the CRLReason MUST NOT be certificateHold (6).

Which made me think the language applied only to CRLs and OCSP issued after 
9-30. However, the language does only reference certificateHold and not the 
inclusion of reasonCode language.

That was the analysis I had anyway - that any CRLs and OCSP published after 
9-30 had to have  reasonCode.

-----Original Message-----
From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> On 
Behalf Of Rob Stradling via dev-security-policy
Sent: Wednesday, September 30, 2020 9:59 AM
To: dev-security-policy@lists.mozilla.org
Subject: Mandatory reasonCode analysis

Starting today, the BRs require a reasonCode in CRLs and OCSP responses for 
revoked CA certificates.  Since crt.sh already monitors CRLs and keeps track of 
reasonCodes, I thought I would conduct some analysis to determine the level of 
(non)compliance with these new rules.

It's not clear to me if (1) the new BR rules should be applied only to CRLs and 
OCSP responses with thisUpdate timestamps dated today or afterwards, or if (2) 
every CRL and OCSP response currently being served by distribution points and 
responders (regardless of the thisUpdate timestamps) is required to comply.  
(I'd be interested to hear folks' opinions on this).

This gist contains my crt.sh query, the results as .tsv, and a .zip containing 
all of the referenced CRLs:
https://gist.github.com/robstradling/3088dd622df8194d84244d4dd65ffd5f


--
Rob Stradling
Senior Research & Development Scientist
Email: r...@sectigo.com
Bradford, UK
Office: +441274024707
Sectigo Limited

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