Mike,
 

While the existence of the delayed revocation protocol might make delayed 
revocation seem more acceptable, I think that it currently serves a useful 
purpose (or could, if complied with in good faith) in helping other CAs 
identify scenarios that they should prepare for themselves, and can shine 
light on cases where the CA is misaligned with the purpose and requirements 
of the Mozilla root program. Imagine how much harder people would have to 
fight to get useful information about a failure to revoke on time, if there 
wasn’t that set of Mozilla expectations to start from…


I'm not sure I fully agree. I absolutely agree most delayed revocation 
reports are not up to how I interpret Mozilla's current expectations, and 
certainly fully see the merits with respect to it being useful in shining a 
light on which CAs are not aligned with the purpose and spirit of being a 
webPKI CA before it gets to the point of malicious misissuance (as we have 
seen in spades in a recent example). Yet I think the large number of 
delayed revocation events that explicitly cite the Mozilla policy first and 
foremost for why there is a delay is evidence that this policy is having a 
detrimental effect on the webPKI. 

If this language did not exist, the pressure on CA's is to "not delay 
revocation at all, or, if we do, risk being distrusted [or have our 
certificate lifetimes capped]." And if they decide that it truly is an 
exceptional case, then to avoid that distrust action (or lifetime capping 
or whatever) they are strongly incentivized to provide as much detail as 
possible for why these specific certificates were not revoked on time. 
Instead of having a policy, that due to the wide definition of "critical 
infrastructure" is taken as carte blanche permission to delay, which 
clearly seems to be the opinion of some CAs.

Put another way: as you so eloquently described above, ultimately it is up 
to each subscriber -- not the CA -- to weigh the risks and benefits of how 
they are acquiring and deploying certificates, and to act accordingly. That 
only works if the subscriber is exposed to the actual "risks" associated 
with webPKI certificates, which in turn comes from CAs, as custodians of 
public trust, actually enforcing the rules. The current Mozilla delayed 
revocation policy, based on the evidence in the many delayed revocation 
reports, is providing way too much leeway to CAs who are, in turn, not 
applying appropriate back pressure on subscribers to assess risks and plan 
accordingly. 

If the objective is to make sure other CAs and the community is learning as 
much as possible from events when they happen, it might instead be worth 
incorporating language that incident reports [of any variety] must include 
per-certificate and per-subscriber breakdowns of root causes / effects. 
This would be beneficial not just in revocation cases, but in others as 
well.

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