The current subject line for GitHub Mozilla PKI Policy Issue #251
<https://github.com/mozilla/pkipolicy/issues/251> is "Edit MRSP 4.1 to
clarify full CRL publication issues in the CCADB".

Currently, section 4.1 of MRSP
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#41-additional-requirements>
states:

Effective October 1, 2022, CA operators with intermediate CA certificates
that are capable of issuing TLS certificates chaining up to root
certificates in Mozilla's root store SHALL populate the CCADB fields under
"Pertaining to Certificates Issued by This CA" with either the CRL
Distribution Point for the "Full CRL Issued By This CA" or a "JSON Array of
Partitioned CRLs"

Requests have been made to clarify this policy for at least two situations
where the CA is not actively issuing certificates: (1) the CA has not yet
issued certificates, and (2) the CA issued certificates in the past, but is
no longer issuing certificates, e.g. a "dormant" CA (provided that all
previously issued certificates have since expired).

The language proposed thus far would address the first scenario by
adding "within
7 days of such intermediate CA issuing its first certificate". Language
should be developed that addresses the second scenario.

One suggestion might be to change the phrase directly above to read
something like:

"unless no certificates have been issued by the intermediate CA or all
previously issued certificates under that intermediate CA have expired, in
which case, the CA operator shall populate the CCADB fields within 7 days
of such intermediate CA issuing a certificate."

Thoughts? Discussion?

Thanks,
Ben

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