Thanks, Andrew

I think it will be really helpful for OCSP Watch to monitor compliance
based on precertificates going forward.

Ben

On Fri, Apr 22, 2022 at 7:37 AM Andrew Ayer <[email protected]> wrote:

> I am concerned by effective date of October 1, 2022 for the last two
> bullet points of Section 5.4 (Precertificates).  Although some CAs have
> argued that these are "new" requirements, they haven't explained _why_
> they need this amount of time to become compliant, and for the reasons I
> previously stated
> <
> https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/-yDazqfWzN8/m/FvyoY6KfCQAJ
> >,
> such a long phase-in period doesn't seem justifiable given the history.
>
> The second-to-last bullet point is especially important, and if Mozilla
> doesn't enforce it until October, then for the next 5+ months, CAs will
> be allowed to leave misissued certificates unrevoked by simply claiming
> that they never issued a final certificate, which no one has any way of
> verifying.
>
> Note that both of these bullet points are already implied by RFC6962's
> statement that precertificates create a binding intent to issue a
> certificate.  CAs should not assume that other root programs have made
> or will make an exception to RFC6962's implication.  Apple and Chrome
> likely have strong opinions here, since as CT-enforcing UAs, their
> users have the most to lose from a weakening of a precertificate's
> meaning.  Unless these other root programs say otherwise, I will
> continue reporting noncompliance observed by OCSP Watch even when the
> only evidence of issuance is a precertificate.
>
> Regards,
> Andrew
>

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