> While tightening up the language is of course possible, it would still remain 
> the case that there are a number of circumstances in which a CA may not have 
> a reliable means of communication with the subscriber.  For example, Let's 
> Encrypt does not require subscribers to provide any contact details in order 
> to register an account.

For those CAs which do not collect any information for Subscribers, I would be 
interested to learn how BR 9.6.3 (7) is fulfilled:

"7. Responsiveness: An obligation to respond to the CA’s instructions 
concerning Key
Compromise or Certificate misuse within a specified time period."

Thanks,
Corey


-----Original Message-----
From: [email protected] <[email protected]> On 
Behalf Of Matt Palmer
Sent: Wednesday, December 1, 2021 4:47 AM
To: [email protected]
Subject: Re: Revocation Reason Codes for TLS End-Entity Certificates

Hi Kathleen,

On Tue, Nov 30, 2021 at 01:43:50PM -0800, Kathleen Wilson wrote:
> If someone other than the Subscriber requests revocation by providing 
> verifiable evidence that the Subscriber's Private Key corresponding to 
> the Public Key in the Certificate suffered a Key Compromise, then the 
> CA MUST make the information regarding its intent to revoke available 
> to the Subscriber before revoking the certificate,

I'm curious about the background that caused this particular requirement to end 
up in here.  It doesn't seem relevant to the specification of revocation reason 
codes.

As an aside, I'm also not in favour of it in general, for a couple of reasons.  
Firstly, the wording is vague, both in the means by which the action may be 
executed, as well as the timeframe.  Posting a list of certs to be revoked at 
an obscure URL five seconds before publishing the CRL would seem to fit the 
strict interpretation of this requirement, but it doesn't seem to serve any 
practical purpose.

While tightening up the language is of course possible, it would still remain 
the case that there are a number of circumstances in which a CA may not have a 
reliable means of communication with the subscriber.  For example, Let's 
Encrypt does not require subscribers to provide any contact details in order to 
register an account.

- Matt

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