As a second paragraph, I'm considering inserting: The process outlined herein applies to organizations that either: do not already operate a root CA or subCA that is trusted by the Mozilla root program, or already operate within the root program, but seek a new subCA certificate that will grant them technical capability for the issuance of certificates that they previously did not have. Specifically, this process must be followed when an organization does not control a subCA or Root CA certificate that grants capability to issue certificates of one or more of the following types and the new subCA certificate will grant such capability: S/MIME (Email trust bit), (DV/IV/OV) TLS Server Authentication (Websites trust bit), and/or EV TLS Server Authentication (Websites trust bit with EV-enablement).
And as a fifth paragraph, I'm considering adding: And, if a new or modified CA certificate is to be issued to the same operator having already undergone the full process for the type of end entity certificates being issued, then there is no need to repeat this process. For example, if the prior process only involved a review for issuance of email certificates, and the CA operator then wants a CA certificate with the serverAuth EKU in order to issue server certificates, then that part of the review process not fully performed must be repeated because of the different requirements and performance expectations. And vice versa, if the CA operator were first approved to issue server certificates and then wanted a CA certificate with the emailProtection EKU to issue email certificates, then any relevant part of the review process that was missed would need to be performed. On Thu, Nov 11, 2021 at 10:26 AM Corey Bonnell <[email protected]> wrote: > > Is it necessary to start a new discussion every time a new CA > Certificate is about to be issued for that same type and class, or not ? > Ben, would it make sense to add a new section to address this issue so > there is no confusion? > > > > One major downside of mandating a public discussion for the issuance of a > subCA certificate of the same type and class is one of agility: the > requirement for public discussion would be a disincentive for shorter subCA > certificate validity periods. Additionally, if revocation is required for a > subCA certificate, the requirement for a public discussion and approval for > its replacement would likely be an impediment to the timely revocation and > replacement process. > > > > Thanks, > > Corey > > > > *From:* Dimitris Zacharopoulos <[email protected]> > *Sent:* Thursday, November 11, 2021 11:47 AM > *To:* Corey Bonnell <[email protected]>; Ben Wilson < > [email protected]> > *Cc:* [email protected] <[email protected]> > *Subject:* Re: Policy 2.8: MRSP Issue #233: Wiki page documenting process > for reviewing externally operated subordinate CAs > > > > One more issue to clarify is what happens during the SubCA renewal process > (and what "renewal" means), or issuance of another subCA to an organization > that has already been approved for the same certificate type (server or > email) and class (EV or not for server certificates). > > Is it necessary to start a new discussion every time a new CA Certificate > is about to be issued for that same type and class, or not ? Ben, would it > make sense to add a new section to address this issue so there is no > confusion? > > Also, where would the information about the unconstrained external SubCAs > that have passed public discussion and have been approved or denied be > located? > > > Thanks, > Dimitris. > > On 11/11/2021 3:21 μ.μ., 'Corey Bonnell' via > [email protected] wrote: > > Hi Ben, > > I think the expectation can be clarified by amending the paragraph > starting with “The process outlined herein applies to subCA operators not > already in the Mozilla root program”. I suggest explicitly mentioning the > three different types of trust, namely Email, (non-EV) Websites, and EV > Websites and requiring the process be followed whenever an organization is > to receive a subCA certificate that grants one or more of those technical > capabilities that the organization did not have in the Mozilla root > program. As a concrete proposal: > > > > “The process outlined herein applies to organizations that do not control > a Root or subCA certificate trusted by the Mozilla root program. > Additionally, the process outlined herein applies to organizations that > control a subCA or Root CA certificate in Mozilla’s root program but the > new subCA certificate will grant technical capability for the issuance of > additional types of certificates. Specifically, the process outlined herein > MUST be followed when an organization does not control a subCA or Root CA > certificate that grants capability to issue certificates of one or more of > the following types and the new subCA certificate will grant such > capability: S/MIME (Email trust bit), (DV/IV/OV) TLS Server Authentication > (Websites trust bit), and/or EV TLS Server Authentication (Websites trust > bit with EV-enablement).” > > > > Thanks, > > Corey > > > > *From:* Ben Wilson <[email protected]> <[email protected]> > *Sent:* Wednesday, November 10, 2021 5:46 PM > *To:* Corey Bonnell <[email protected]> > <[email protected]> > *Cc:* [email protected] <[email protected]> > <[email protected]> > *Subject:* Re: Policy 2.8: MRSP Issue #233: Wiki page documenting process > for reviewing externally operated subordinate CAs > > > > Hi Corey, > > > > I think I'll disagree with your conclusion that there is no need to > perform a review of Sub CA B for issuance of a new intermediate certificate > to it with the serverAuth EKU. > > > > Let's assume that Root CA A already has both the websites bit and the > email bit enabled by Mozilla. And assume that the review-and-comment > process for Sub CA B focused only on the enablement of that CA for S/MIME > certificate issuance. What if there had not been a thorough review of Sub > CA B's Compliance Self Assessment (Required Documentation > <https://wiki.mozilla.org/CA/Subordinate_CA_Checklist#Required_Documentation> > #6) because much of the assessment applies only to server certificate > issuance (i.e. what if the assessment had been filled with a lot of > "N/A"s)? Then, the prior public discussion was insufficient.("Prior to > public discussion, the root CA operator must confirm that it has verified > all of the following information, which must be provided when the root CA > operator starts the public discussion.") > > > > However, all of this might be different if the review of Sub CA B was > thorough enough to cover server certificate issuance. > > > > I suppose I can make that more clear on the wiki page. I also welcome any > suggestions. > > > > Thanks, > > Ben > > > > > > On Tue, Nov 9, 2021 at 3:30 PM Corey Bonnell <[email protected]> > wrote: > > Hi Ben, > > A scenario came to mind that may deserve further clarity in the text, so I > wanted to raise it here. Suppose Root CA “A” kicks off the > information-gathering and review process for Sub CA “B” (as outlined on the > Wiki page) for the issuance of a subordinate CA certificate containing > solely id-kp-emailProtection. The discussion ends favorably and Sub CA B is > marked in CCADB as an “approved” organization. Some time later, Sub CA B > wishes to obtain a subordinate certificate containing id-kp-serverAuth. > Since this organization has previously been approved, according to the > proposed language, there is no need to undergo the review and approval > process again despite the difference in technical capability and audit > requirements of the subordinate CAs. > > > > Is this an accurate read of the proposed language? > > > > Thanks, > > Corey > > > > *From:* [email protected] <[email protected]> *On > Behalf Of *Ben Wilson > *Sent:* Monday, November 1, 2021 2:58 PM > *To:* [email protected] <[email protected]> > *Subject:* Re: Policy 2.8: MRSP Issue #233: Wiki page documenting process > for reviewing externally operated subordinate CAs > > > > I am proposing that we create a link in the MRSP to the process for review > and approval of third-party externally operated CAs as indicated in the > following commit: > > > https://github.com/BenWilson-Mozilla/pkipolicy/commit/9efa9e73f6cff7924d1ed856eadd1902f31bd458 > > > > On Thu, Oct 28, 2021 at 2:56 PM Ben Wilson <[email protected]> wrote: > > 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 #233 > <https://github.com/mozilla/pkipolicy/issues/233>. > > > > I have re-published the wiki page for the process of reviewing and > approving externally operated subordinate CAs. Here is the URL: > > > https://wiki.mozilla.org/CA/Subordinate_CA_Checklist#Process_for_Review_and_Approval_of_Externally_Operated_Subordinate_CAs > > > > This issue is also related to an m.d.s.p. email that I sent and comments > received with a subject line: Process for Considering Externally Operated > Subordinate CAs > <https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/AA5G1bzOwZQ/m/v4i0_wj9BAAJ> > . > > > > Please provide any additional comments you may have regarding the review > and approval process for externally operated subordinate CAs. > > > > Thanks, > > > > Ben Wilson > > Mozilla Root Program Manager > > > > > > -- > 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/CA%2B1gtaZX%2B_vWSyZe2tMGREjurRRV7y66AVMQyLkPz8LE4BbsUw%40mail.gmail.com > <https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/CA%2B1gtaZX%2B_vWSyZe2tMGREjurRRV7y66AVMQyLkPz8LE4BbsUw%40mail.gmail.com?utm_medium=email&utm_source=footer> > . > > -- > You received this message because you are subscribed to the Google Groups > "[email protected]" <[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/DM6PR14MB2186D6FBA3B3CC7FD7EAF7C492949%40DM6PR14MB2186.namprd14.prod.outlook.com > <https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/DM6PR14MB2186D6FBA3B3CC7FD7EAF7C492949%40DM6PR14MB2186.namprd14.prod.outlook.com?utm_medium=email&utm_source=footer> > . > > > -- You received this message because you are subscribed to the Google Groups "[email protected]" group. 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