Hi Oscar,

It would be very helpful if you filed a Bugzilla bug here -
https://bugzilla.mozilla.org/enter_bug.cgi?product=NSS&component=CA+Certificate+Compliance.

In the Summary field, start the subject with "TWCA: [a brief title for the
violation]"
Then, in the Description/Comment field, explain your findings.

Alternatively, you can post your findings here, and I will open the Bug in
Bugzilla for you.

Thanks,

Ben Wilson


On Mon, Nov 1, 2021 at 2:15 PM Oscar Koeroo <[email protected]> wrote:

> Ryan and Ben,
>
> Thank you for your thorough analyses in your replies. How do I best
> proceed into filing a complaint on the found and confirmed non-compliance
> to the baseline requirements?
>
>
> On 01/11/2021 18:21, Ryan Sleevi wrote:
>
> Oscar:
>
> The likely reason for your scans is the result of CA/Browser Forum Ballot
> SC31, https://cabforum.org/2020/07/16/ballot-sc31-browser-alignment/ ,
> which was adopted as part of BRs v1.7.1. Effective 2020-09-30, all
> Subscriber certificates MUST include a CA/Browser Forum Reserved Policy OID
> (see Section 1.2.2 for the effective dates, referencing Section 7.1.6.4).
> Given that the majority of certificates have been issued since then, this
> would likely explain your scan.
>
> Prior to this, in BRs 1.7.0, Section 7.1.6.4 permitted CAs to use EITHER a
> CA/Browser Forum reserved OID OR a CA-specified OID in their CP/CPS.
> Understandably, this makes it difficult-to-impossible for relying parties
> to have interoperable confidence, hence the changes in 1.7.1 that aligned
> with existing browser requirements.
>
> In particular, prior to BRs 1.7.1, Microsoft had this as a requirement in
> their root program, at https://aka.ms/rootcert.
>
> Thus, to answer your question regarding https://crt.sh/?id=2884243786
>
> 1. If before 2020-09-30, and it contains id-kp-serverAuth and lacks a
> CA/BF OID
>   a. It was in violation of Microsoft's root program requirements.
>   b. If you cannot discover in the CP/CPS in effect at the time of
> issuance that the CA affirmatively states this OID complies to the BRs or
> EVGs, then it was in violation of the Baseline Requirements
> 2. If on-or-after 2020-09-30, and it contains id-kp-serverAuth and lacks a
> CA/BF OID, it is in violation of the Baseline Requirements
>
> Hope that helps clarify.
>
> The CP/CPS disclosed in CCADB is
> https://www.twca.com.tw/picture/file/05271722-TWCAGLOBALCPSV13EN.pdf ,
> which would appear out of compliance with Mozilla's Root Store Policy
> (Specifically, Policy 3.3(4) ). It's unclear if Mozilla relies on CCADB
> disclosures to achieve that requirement, although
> https://www.twca.com.tw/repository links
> to 11061501-TWCAGLOBALCPSV13EN.pdf as their most recent CPS (which would
> also be out of compliance, as best I can tell). I double checked the CCADB
> disclosures for the Root, https://crt.sh/?id=8559119 , and while they
> _also_ list different versions and URLs compared to
> https://www.twca.com.tw/repository, they also appear to be out of
> compliance.
>
> Ignoring this failure to update issue for a second, as Ben has
> highlighted, 1.3.6.1.4.1.40869.1.1.25 is disclosed as a "Device
> Certificate". It's unclear if TWCA is asserting this policy OID complies
> with the Baseline Requirements, given they also list AATL-related
> certificates ( 1.3.6.1.4.1.40869.1.1.26 ), and presumably the latter do not
> comply to the Baseline Requirements.
>
> Thus, it's entirely possible that this certificate is misissued. Hopefully
> the above steps allow you to reproduce the investigation and reach your own
> determination, based on the available facts.
>
> On Mon, Nov 1, 2021 at 10:56 AM Ben Wilson <[email protected]> wrote:
>
>> One of their CPSes says that Policy OID is for a "Device Certificate"
>> (Assurance Level 2), which is separate than a TLS server certificate with
>> an OID of 1.3.6.1.4.1.40869.1.1.21 (Assurance Level 3), both are very
>> similar, but I don't know what the distinction is between the two types.
>>
>> On Mon, Nov 1, 2021 at 7:39 AM Oscar Koeroo <[email protected]> wrote:
>>
>>> Hello,
>>>
>>> I've been doing some scanning on a few million pages and consistently
>>> see the policy OIDs for DV, IV, OV, QWAC in the scopes of ETSI, CA/B or
>>> others.
>>>
>>> The certificate found on the site "https://ettoday.net"; I can't
>>> determine the assurance policy.
>>>
>>> Example certificate:
>>> Subject: CN=*.ettoday.net,OU=RD,O=ET New Media Holding Co.\,
>>> Ltd.,L=Taipei,ST=Taiwan,C=TW
>>> Issuer: CN=TWCA Secure SSL Certification Authority,OU=Secure SSL
>>> Sub-CA,O=TAIWAN-CA,C=TW
>>> Serial number: 95559031384477517871019103745820225456
>>>
>>> The only policy OID set is: 1.3.6.1.4.1.40869.1.1.25  ['www.twca.com.tw
>>> ']
>>>
>>> How should I qualify this certificate? Or is this a misissuance? A
>>> clarification would be great on how to determine this.
>>>
>>> The OID is also not part of this quite complete list of policy OIDs
>>> https://github.com/zmap/constants
>>>
>>> Your guidance would be appreciated.
>>>
>>>
>>> Kind regards,
>>> Oscar Koeroo
>>>
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>>>
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