Below is a list of issues that I propose be addressed in the next version
(2.7.1) of the Mozilla Root Store Policy (MRSP). There are currently 73
issues related to the MRSP listed here:
https://github.com/mozilla/pkipolicy/issues. So far, I have identified 13
items to consider for this policy update; which are tagged as v.2.7.1 in
GitHub (https://github.com/mozilla/pkipolicy/labels/2.7.1). I will
appreciate your input on this list as to whether there are issues that
should be added or removed. Then, based on the list, I will start a
separate discussion thread in mozilla.dev.security.policy for each issue.

#139 <https://github.com/mozilla/pkipolicy/issues/139> - Audits are
required even if no longer issuing - Clarify that audits are required until
the CA certificate is revoked, expired, or removed. Related to Issue #153.

#147 <https://github.com/mozilla/pkipolicy/issues/147> - Require EV audits
for certificates capable of issuing EV certificates – Clarify that EV
audits are required for all intermediate certificates that are technically
capable of issuing EV certificates, even when not currently issuing EV
certificates.

#153 <https://github.com/mozilla/pkipolicy/issues/153> – Cradle-to-Grave
Contiguous Audits – Specify the audits that are required from Root key
generation ceremony until expiration or removal from Mozilla’s root store.
Related to Issue #139.

#154 <https://github.com/mozilla/pkipolicy/issues/154> - Require Management
Assertions to list Non-compliance – Add to MRSP 2.4 “If being audited to
the WebTrust criteria, the Management Assertion letter MUST include all
known incidents that occurred or were still open/unresolved at any time
during the audit period.”

#173 <https://github.com/mozilla/pkipolicy/issues/173> - Strengthen
requirement for newly included roots to meet all past and present
requirements – Add language to MRSP 7.1 so that it is clear that before
being included CAs must comply and have complied with past and present
Mozilla Root Store Policy and Baseline Requirements.

#186 <https://github.com/mozilla/pkipolicy/issues/186> - Clarify MRSP 5.3
Requirement to Disclose Self-signed Certificates – Clarify that self-signed
certificates with the same key pair as an existing root meets MRSP 5.3’s
definition of an intermediate certificate that must be disclosed in the
CCADB.

#187 <https://github.com/mozilla/pkipolicy/issues/187> - Require disclosure
of incidents in Audit Reports –  To MRSP 3.1.4 “The publicly-available
documentation relating to each audit MUST contain at least the following
clearly-labelled information: “ add “11. all incidents (as defined in
section 2.4) that occurred or were still open/unresolved at any time during
the audit period, or a statement that the auditor is unaware of any;”

#192 <https://github.com/mozilla/pkipolicy/issues/192> - Require
information about auditor qualifications in the audit report – Require
audit statements to be accompanied by documentation of the auditor’s
qualifications demonstrating the auditor’s competence and experience.

#205 <https://github.com/mozilla/pkipolicy/issues/205> - Require CAs to
publish accepted methods for proving key compromise – Require CAs to
disclose their acceptable methods for proving key compromise in section
4.9.12 of their CPS.

#206 <https://github.com/mozilla/pkipolicy/issues/206> - Limit re-use of
domain name verification to 395 days – Amend item 5 in MRSP 2.1 with “and
verify ownership/control of each dNSName and iPAddress in the certificate's
subjectAltName at intervals of 398 days or less;”

#207 <https://github.com/mozilla/pkipolicy/issues/207> - Require audit
statements to provide information about which CA Locations were and were
not audited, and the extent to which they were (or were not) audited

#211 <https://github.com/mozilla/pkipolicy/issues/211> - Align OCSP
requirements in Mozilla's policy with the section 4.9.10 of the Baseline
Requirements
#218 <https://github.com/mozilla/pkipolicy/issues/218> Clarify CRL
requirements for End Entity Certificates – For CRLite, Mozilla would like
to ensure that it has full lists of revoked certificates. If the CA uses
partial CRLs, then require CAs to provide the URL location of their full
and complete CRL in the CCADB.

Ben Wilson
Mozilla Root Program Manager
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