Looks like I made a copy-and-paste error for item 3, so correcting here:

Therefore, I think that first paragraph should be changed to:
All certificates that are capable of being used to issue working server or 
email 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 be publicly disclosed in the CCADB.



On Monday, November 15, 2021 at 11:40:58 AM UTC-8 Kathleen Wilson wrote:

> I feel like this item needs to be further discussed...
>
> 1) section 1.1 of Mozilla's Root Store Policy (MRSP) 
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#11-scope>
>  
> limits the scope of the policy to "intermediate certificates which are 
> technically capable of issuing working server or email certificates". So my 
> understanding is that the proposed changes would mean that all intermediate 
> certificates which are technically capable of issuing working server or 
> email certificates must be disclosed in the CCADB, even if they are name 
> constrained. And the proposed changes would NOT mean that intermediate 
> certificates would need to be disclosed in the CCADB when they contain an 
> Extended Key Usage (EKU) extension which does not contain any of these 
> KeyPurposeIds: anyExtendedKeyUsage, id-kp-serverAuth, 
> id-kp-emailProtection.  
> Correct?
>
> 2) Just wondering... How do you all think that requiring disclosure of 
> technically-constrained intermediate certs in the CCADB improves security 
> for end-users?
>
>
>
>> I have made an attempt to address this further with some commits in my 
>> GitHub repository:
>>
>>
>> https://github.com/mozilla/pkipolicy/compare/1829373903c8d58246c781ee11ea77d6d386985a...
>> e6550dba22ed38ac6bdd33677a8bf3d2f00e75de
>>
>>
> 3) regarding the proposed change in the first paragraph of section 5.3 from
> "Certificate Program MUST be operated in accordance with this policy and 
> MUST either be technically constrained or be publicly disclosed and 
> audited."
> to
> "Certificate Program MUST be operated in accordance with this policy and 
> MUST either be technically constrained or be audited."
>
> My interpretation of the original sentence was: "MUST either be 
> technically constrained or (be publicly disclosed and audited)."
> meaning that 3rd-party audit statements would have to be provided.
> I do NOT interpret it as meaning that technically-constrained intermediate 
> certificates do not have to be audited at all. The BRs provide specific 
> requirements for the oversight of technically-constrained intermediate 
> certificates that I view as the minimum oversight that should be done for 
> such intermediate certificates.
>
> Therefore, I think that first paragraph should be changed to:
> All certificates that are capable of being used to issue new certificates 
> which are technically capable of issuing working server or email 
> 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 be publicly disclosed in the CCADB.
>
>
> 4) Regarding these changes:
> > Move the 4th paragraph in MRSP § 5.3 to the first paragraph of § 5.3.2. 
> > Move content from the second bullet in MRSP § 5.3.2 to the first 
> paragraph and eliminate the bulleted list.
>
> I think the new text of section 5.3.2  looks OK, except
>
> 4.a) Move this to its own paragraph: 
> Name Constrained CA certificates that were exempt from disclosure in 
> previous versions of this policy MUST be disclosed in the CCADB prior to 
> July 1, 2022.
>
> 4.b) We CANNOT delete the sentence, "All disclosure MUST be made freely 
> available..."
> We must keep that text, especially for audit statements. So keep this text 
> as a separate paragraph:
>
> 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.
>
> Thanks,
> Kathleen
>
>

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