All,

This email introduces another issue selected to be addressed in 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)

This is Github Issue #229 <https://github.com/mozilla/pkipolicy/issues/229>.


This issue was previously discussed here:
https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/XsVpyOGlagE/m/xw8JGJYZBAAJ
.

The proposal is that by July 1, 2022, CAs would have to report all
technically constrained CAs in the CCADB.

Currently, MRSP § 5.3
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#53-intermediate-certificates>
says,
"All certificates that are capable of being used to issue new certificates
and that directly or transitively chain to a CA 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.
...
Thus, the operator of a CA certificate trusted in Mozilla’s CA Certificate
Program MUST disclose in the CCADB all non-technically constrained CA
certificates they issue that chain up to that CA certificate trusted in
Mozilla’s CA Certificate Program. This applies to all non-technically
constrained CA certificates, including those that share the same key pair
whether they are self-signed, doppelgänger, reissued, cross-signed, or
other roots."

MRSP§ 5.3.2
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#532-publicly-disclosed-and-audited>
would require a slight modification, as well.  It states, "All certificates
that are capable of being used to issue new certificates, that are not
technically constrained, and that directly or transitively chain to a
certificate included in Mozilla’s root program: ... MUST be publicly
disclosed in the CCADB by the CA that has their certificate included in
Mozilla’s root program."

I have made an attempt to address this further with some commits in my
GitHub repository:

https://github.com/mozilla/pkipolicy/compare/1829373903c8d58246c781ee11ea77d6d386985a...
e6550dba22ed38ac6bdd33677a8bf3d2f00e75de

Among other changes, these commits:
1. Move the 4th paragraph in MRSP § 5.3 to the first paragraph of § 5.3.2.
2. Move content from the second bullet in MRSP § 5.3.2 to the first
paragraph and eliminate the bulleted list.
3. Delete the sentence, "All disclosure MUST be made freely available and
without additional requirements, including, but not limited to,
registration, legal agreements, or restrictions on redistribution of the
certificates in whole or in part" because it no longer makes sense in the
context of CA certificate disclosure. (Similar language could be added to MRSP
§3.1.4
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#314-public-audit-information>,
but it already requires publicly available audit documentation.)

Please provide any additional comments you may have regarding the
requirement that CAs disclose all subordinate CAs, regardless of whether
they are technically constrained.

Thanks,

Ben Wilson
Mozilla Root Program Manager

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