Hello!

Please find my comments inline.

From: [email protected] <[email protected]> On 
Behalf Of Kathleen Wilson
Sent: Dienstag, 16. November 2021 00:24
To: [email protected]
Subject: Re: Policy 2.8: MRSP Issue #229: Disclose Technically Constrained CAs 
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://eur01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.mozilla.org%2Fen-US%2Fabout%2Fgovernance%2Fpolicies%2Fsecurity-group%2Fcerts%2Fpolicy%2F%2311-scope&data=04%7C01%7Crufus.buschart%40siemens.com%7C8e694116e6a141e74e6e08d9a88ef7ca%7C38ae3bcd95794fd4addab42e1495d55a%7C1%7C0%7C637726154263132716%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=AYJ3nbJyx0S4XpgxjqMOW4BUMjduSaWycRkrIBHumvw%3D&reserved=0>
 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?

[>] This was at least my original intention

2) Just wondering... How do you all think that requiring disclosure of 
technically-constrained intermediate certs in the CCADB improves security for 
end-users?

[>] In my opinion, we will get a much better transparency what is there out in 
the field. Currently there is a big, big unknown. And this risky since these 
name-constrained CAs are not externally audited but only undergo sample testing 
acc. BR 8.7. last two sentences.


I have made an attempt to address this further with some commits in my GitHub 
repository:
https://github.com/mozilla/pkipolicy/compare/1829373903c8d58246c781ee11ea77d6d386985a...e6550dba22ed38ac6bdd33677a8bf3d2f00e75de<https://eur01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fmozilla%2Fpkipolicy%2Fcompare%2F1829373903c8d58246c781ee11ea77d6d386985a...e6550dba22ed38ac6bdd33677a8bf3d2f00e75de&data=04%7C01%7Crufus.buschart%40siemens.com%7C8e694116e6a141e74e6e08d9a88ef7ca%7C38ae3bcd95794fd4addab42e1495d55a%7C1%7C0%7C637726154263132716%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=TpOCo%2Bh6fPISeRwIswYMycbkj72%2FHAgJSm1z8QWr6wM%3D&reserved=0>


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.
[>] Yes, but the minimum oversight is slim: assess the adherence to the CP/CPS 
and perform a sample testing on the issued 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.
[>] 👍🏻


With best regards,
Rufus Buschart

Siemens AG
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