Ben,
In addition to your concerns (which I share) about whether it’s actually possible to encode this sort of thing in policy successfully, I’ll note that your proposed text has a slight loophole: even though someone agrees to abide by their obligations in the T&Cs, they may not actually be complying with the T&Cs, and, to further complicate things, whether they are in compliance or not may be a matter that is in dispute between the parties. As written, the policy proposal would forbid revocation in cases where an entity is violating the T&Cs but refuses to admit it, as the entity can claim they are exempt from revocation because they “agreed to the T&Cs”. That would be a very unfortunate circumstance. -Tim From: [email protected] <[email protected]> On Behalf Of Ben Wilson Sent: Tuesday, October 19, 2021 4:54 PM To: [email protected] <[email protected]> Subject: Re: Policy 2.8: MRSP Issue #129: Require non-discriminatory CA conduct As an initial edit, I am proposing that we add the following language as a new subsection 6 to MRSP section 2.1 - "[CAs SHALL] provide services on a non-discriminatory basis to all applicants who meet the requirements and agree to abide by their obligations as specified in the CA's terms and conditions". See https://github.com/BenWilson-Mozilla/pkipolicy/commit/fab61408608feed365a9446ac47560a34c06cf85 <https://github.com/BenWilson-Mozilla/pkipolicy/commit/fab61408608feed365a9446ac47560a34c06cf85> On Thu, Oct 7, 2021 at 6:06 PM Ben Wilson <[email protected] <mailto:[email protected]> > wrote: All, This email is the first in a series of discussions concerning the next version of the Mozilla Root Store Policy (MSRP), version 2.8, to be published in 2022. (See https://github.com/mozilla/pkipolicy/labels/2.8) Issue #129 <https://github.com/mozilla/pkipolicy/issues/129> in GitHub proposes that we add a policy of non-discrimination to the MRSP. This particular issue arose from discussions of whether CAs should be allowed to arbitrarily refuse to issue or to revoke certificates. (The situation involved an EV certificate for Stripe, Inc., of Kentucky, https://groups.google.com/g/mozilla.dev.security.policy/c/NjMmyA6MxN0/m/asxTGD3dCAAJ). Many of you argued that CAs should objectively and non-arbitrarily apply the issuance and revocation standards of the CA/Browser Forum. The full discussion can be read in the email thread referenced above, so I'll forego any attempt to recap. Potential policy language can be paraphrased from the suggestion made in Issue #129, which was to base language on ETSI 319 401--"Practices under which the CA operates SHALL be non-discriminatory. The CA SHALL make its services accessible to all applicants who meet the requirements and agree to abide by their obligations as specified in the CA's terms and conditions." Alternative wording might be something like, "Decisions not to issue or to revoke a certificate should be based on the unbiased application of the CA/Browser Forum's requirements using the objective criteria stated therein," OR "CAs shall apply the CA/Browser Forum’s issuance and revocation requirements in a non-arbitrary manner." Is a variation of the language above sufficient? What do you suggest as language? Should it be inserted somewhere in section 2 <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#2-certificate-authorities> of the MRSP? Thoughts? Thanks, Ben -- You received this message because you are subscribed to the Google Groups "[email protected] <mailto:[email protected]> " group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected] <mailto:[email protected]> . To view this discussion on the web visit https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/CA%2B1gtabsOaZP88JXg5qP%2BGjZoAvc0n4_Y2Y%2B63KF94h2OoTDDQ%40mail.gmail.com <https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/CA%2B1gtabsOaZP88JXg5qP%2BGjZoAvc0n4_Y2Y%2B63KF94h2OoTDDQ%40mail.gmail.com?utm_medium=email&utm_source=footer> . -- You received this message because you are subscribed to the Google Groups "[email protected]" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. To view this discussion on the web visit https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/DM8PR14MB5237711529EF4B46FF7F6E1883859%40DM8PR14MB5237.namprd14.prod.outlook.com.
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