To provide some additional context, I'm currently conducting a thought
experiment around the following question: What would a CP/CPS look like if
it dedicated one sentence to every requirement (MUST/SHALL/etc) in the BRs,
in the same section that the requirement appears?

A CP/CPS with this format would be very easy to check for compliance with
the requirements, including in contexts like the CCADB Self-Assessment. It
would also be very easy to update when the requirements change.

However, in the process of thinking this through, I've found a number of
places where the "in the same section that the requirement appears" bit
becomes difficult.

For example, the requirement in Section 2.2 stating that Section 4.2 must
contain specific content led me to file this bug
<https://github.com/cabforum/servercert/issues/466>, since it seems like
information regarding CAA should appear in 3.2.2.8, not 4.2. Or for another
example, Section 4.9.3 says that CAs must "provide clear instructions...
through a readily-accessible online means..." (great! Section 4.9.3 of our
CP/CPS is readily accessible online, we can fulfill this requirement right
here and now!) "...and in Section 1.5.2 of their CPS" (wait, so I have to
duplicate the information? that seems inefficient).

On Thu, Nov 30, 2023 at 4:09 PM Wayne Thayer <[email protected]> wrote:

> My recollection is that the intent of this statement was to make it so
> that one doesn't need to search/scroll through a CPS to find the CA's
> problem reporting mechanism. In that context, a reference is undesirable.
>

Thanks, that context is helpful! I was interpreting these requirements less
as "it needs to be in this *specific* place so it's easy to find", and more
as "it needs to be in your CP/CPS, and this is the best place we can think
of for it".

On Thu, Nov 30, 2023 at 4:31 PM Matt Palmer <[email protected]> wrote:

> Take, for example, linking 1.5.2 to 4.9.3.  There's no requirement for
> 4.9.3
> to contain contact information in a form suitable for satisfying the
> requirements of 1.5.2, and while a CPS' 4.9.3 may initially satisfy the
> requirements of 1.5.2, someone revising 4.9.3 in the future, inadvertently
> failing to bear in mind the "link", may modify 4.9.3 in such a way that it
> no longer satisfies the requirements of 1.5.2.
>

I totally get this line of thinking in general, but for me I have to weigh
it against the similar possibility of duplicating the information, and then
having someone in the future update only one instance and create a
contradiction within the document. (See Let's Encrypt's 90d+1s incident for
an example of how having the same information in multiple places can lead
to problems.)

(Also, the example you're using here isn't quite what I'm proposing.
Section 1.5.2 of the CP/CPS would still have the necessary link as required
by Section 1.5.2 of the BRs. It just wouldn't have the *additional* certificate
problem reporting details which are required by Section 4.9.3; it would
just contain a pointer back to Section 4.9.3 for those.)

Since we have two differing opinions expressed so far, I'd still love to
hear from more folks! Thanks,
Aaron

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