All,

Here are the changes mentioned in my previous email on this thread.

https://github.com/BenWilson-Mozilla/pkipolicy/commit/0c4201a2cfab4a68f82c99f4efcdc5bd14bf4785

And here is the blob -
https://github.com/BenWilson-Mozilla/pkipolicy/blob/2.8/rootstore/policy.md

Please provide any comments or questions.

Thanks,

Ben

On Mon, Apr 25, 2022 at 2:26 PM Ben Wilson <[email protected]> wrote:

> All,
>
> During my final read-through, I noticed some things that I want to fix, in
> addition to minor grammar and punctuation (e.g. I'll replace the hyphen
> with a space between "end" and "entity" as requested by Dimitris and in
> accordance with usage in RFC 5280):
>
> 1 - In section 5.2, I'll change "included certificate" to "root
> certificate" or "included root certificate" to clarify that it applies to
> root certificates and not to intermediates and for consistency with the
> Baseline Requirements (see https://github.com/mozilla/pkipolicy/issues/242
> );
> 2 - I'll rephrase the sentence in section 5.3 which says that an
> "intermediate CA operator" "refers to any organization or legal entity ..."
> and move it to section 1 (because it is better to define CA operator
> earlier in the document); and
> 3 - in the much-discussed new section 6.1.1 (TLS revocation reasons) and
> in 6.2 (S/MIME revocation reasons), I'll replace most instances of "CA"
> with "CA operator" - for consistency with the rest of the MRSP.
>
> I'll make those changes now, and then I'll circulate the Github commit
> that shows those changes when I'm done.
>
> Ben
>
> On Fri, Apr 22, 2022 at 8:48 AM Ben Wilson <[email protected]> wrote:
>
>> 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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