> Perhaps add: "And also include any other certificates sharing the same
> private/public key pairs as certificates already included in the
> requirements."  (this covers the situation you mentioned where a
> self-signed certificate shares the key pair of a certificate that chains
> to an included root).

Jakob,

I agree that that would cover that situation, but your proposed language goes 
way, way too far.

Any private CA could cross-certify a publicly-trusted root CA.  How would the 
publicly-trusted CA Operator discover such a cross-certificate?  Why would such 
a cross-certificate be of interest to Mozilla anyway?  Would it really be fair 
for non-disclosure of such a cross-certificate to be considered a policy 
violation?

________________________________
From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> on 
behalf of Jakob Bohm via dev-security-policy 
<dev-security-policy@lists.mozilla.org>
Sent: 29 October 2020 14:57
To: mozilla-dev-security-pol...@lists.mozilla.org 
<mozilla-dev-security-pol...@lists.mozilla.org>
Subject: Re: Policy 2.7.1: MRSP Issue #186: Requirement to Disclose Self-signed 
Certificates

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On 2020-10-29 01:25, Ben Wilson wrote:
> Issue #186 in Github 
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fmozilla%2Fpkipolicy%2Fissues%2F186&amp;data=04%7C01%7Crob%40sectigo.com%7C3bdb53393f1f4056b59e08d87c1aff51%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C637395802683146795%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&amp;sdata=ux32CpUMi7X31uD0W%2BsLV%2Bpgrv3lHgCbdZ%2BhVj2UlbA%3D&amp;reserved=0>
> deals with the disclosure of CA certificates that directly or transitively
> chain up to an already-trusted, Mozilla-included root. A common scenario
> for the situation discussed in Issue #186 is when a CA creates a second (or
> third or fourth) root certificate with the same key pair as the root that
> is already in the Mozilla Root Store. This problem exists at the
> intermediate-CA-certificate level, too, where a self-signed
> intermediate/subordinate CA certificate is created and not reported.
>
> Public disclosure of such certificates is already required by section 5.3
> of the MRSP, which reads, "All certificates that are capable of being used
> to issue new certificates, and which directly or transitively chain to a
> certificate included in Mozilla’s CA Certificate Program, MUST be operated
> in accordance with this policy and MUST either be technically constrained
> or be publicly disclosed and audited."
>
> There have been several instances where a CA operator has not disclosed a
> CA certificate under the erroneous belief that because it is self-signed it
> cannot be trusted in a certificate chain beneath the already-trusted,
> Mozilla-included CA. This erroneous assumption is further discussed in Issue
> #186 
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fmozilla%2Fpkipolicy%2Fissues%2F186&amp;data=04%7C01%7Crob%40sectigo.com%7C3bdb53393f1f4056b59e08d87c1aff51%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C637395802683146795%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&amp;sdata=ux32CpUMi7X31uD0W%2BsLV%2Bpgrv3lHgCbdZ%2BhVj2UlbA%3D&amp;reserved=0>.
>
> The third paragraph of MRSP section 5.3 currently reads, " These
> requirements include all cross-certificates which chain to a certificate
> that is included in Mozilla’s CA Certificate Program."
>
> I recommend that we change that paragraph to read as follows:
>
> "These requirements include all cross-certificates *and self-signed
> certificates (e.g. "Issuer" DN is equivalent to "Subject" DN and public key
> is signed by the private key) that* chain to a CA certificate that is
> included in Mozilla’s CA Certificate Program*, and CAs must disclose such
> CA certificates in the CCADB*.
>
> I welcome your recommendations on how we can make this language even more
> clear.
>

Perhaps add: "And also include any other certificates sharing the same
private/public key pairs as certificates already included in the
requirements."  (this covers the situation you mentioned where a
self-signed certificate shares the key pair of a certificate that chains
to an included root).


Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S.  
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