All,
I came across this section in the wiki that will need to be replaced -
https://wiki.mozilla.org/CA/Subordinate_CA_Checklist#Non-disclosable_Intermediate_Certificates.

Are there any convincing reasons for keeping the current policy of
non-disclosure?
Thanks,
Ben

On Thu, Nov 18, 2021 at 8:02 AM Buschart, Rufus <[email protected]>
wrote:

> 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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