Thanks, Corey and Ben!

We'll start creating CRLs from our production hierarchy very soon, but will
ensure that we don't add those URLs to CCADB until we're confident that the
infrastructure can run continuously.

Aaron

On Thu, Aug 11, 2022, 08:02 Ben Wilson <[email protected]> wrote:

> All,
>
> Mozilla's position is that adding CRL URLs to the CCADB (as required
> effective Oct. 1, 2022, by MRSP section 4.1
> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#41-additional-requirements>)
> will be considered "publishing" them because we will be relying on that
> information in the CCADB to operate CRLite. I have added Issue #251
> <https://github.com/mozilla/pkipolicy/issues/251> to GitHub to address
> this issue more precisely in the next version of the Mozilla Root Store
> Policy. For this, we will use the timeframes from section 4.9.7 of the
> Baseline Requirements, "the CA SHALL update and reissue CRLs at least once
> every seven days ...." (In the future, we might want to see that time frame
> shortened.)
>
> Thanks,
>
> Ben Wilson
> Mozilla Root Store Program
>
>
> On Fri, Aug 5, 2022 at 1:08 PM 'Corey Bonnell' via
> [email protected] <[email protected]> wrote:
>
>> Hi Aaron,
>>
>>
>>
>> > As long as we do not *publish* the CRLs, they are not required to be
>> updated on specific timetables.
>>
>>
>>
>> My understanding is that absent the inclusion of a URI in a CRLDP
>> extension of a Certificate that is subject to the BRs or some other Root
>> Program requirement, there is no obligation by the CA to publish and update
>> CRL-based revocation information on any specific cadence.
>>
>>
>>
>> Given this, I believe that it’s compliant to not publish CRLs that are
>> signed by the CA.
>>
>>
>>
>> Thanks,
>>
>> Corey
>>
>>
>>
>> *From:* 'Aaron Gable' via [email protected] <
>> [email protected]>
>> *Sent:* Thursday, August 4, 2022 4:10 PM
>> *To:* [email protected] <[email protected]>
>> *Subject:* CRL Issuance Frequency for non-published CRLs
>>
>>
>>
>> Hi MDSP,
>>
>>
>>
>> Section 4.9.7 of the Baseline Requirements says (emphasis added):
>>
>>
>>
>> > If the CA *publishes* a CRL, then the CA SHALL update and reissue CRLs
>> at least once every seven days, and the value of the nextUpdate field MUST
>> NOT be more than ten days beyond the value of the thisUpdate field.
>>
>>
>>
>> Let's Encrypt is currently in the final stages of standing up
>> infrastructure to issue and publish CRLs, in compliance with the upcoming
>> Apple and Mozilla root program requirements that go into effect on October
>> 1st.
>>
>>
>>
>> As with many systems, we would like to test this as thoroughly as
>> possible prior to making it fully available. Of course we're already
>> running it in our non-production environment with an untrusted hierarchy of
>> issuers. But there's a risk that, if we were to run the new infrastructure
>> in our production environment and discover some sort of fault, we would not
>> be able to turn it off again due to the reissuance and update requirements.
>>
>>
>>
>> It is our interpretation of the above-quoted text from Section 4.9.7 that
>> this risk does not actually exist. As long as we do not *publish* the
>> CRLs, they are not required to be updated on specific timetables.
>>
>>
>>
>> Does anyone disagree with this interpretation? Are there other
>> requirements that I'm missing that would prevent us from turning the new
>> infrastructure off?
>>
>>
>>
>> Thanks,
>>
>> Aaron
>>
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