All,

Currently, item 5 in section 3.3 of the MRSP
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#33-cps-and-cpses>
says that CPs, CPSes, CP/CPSes must be structured according to RFC 3647
<https://datatracker.ietf.org/doc/html/rfc3647> and "contain no sections
that are blank and have no subsections."  This language is ambiguous
because RFC 3647 contains several, differently numbered outlines. The
current MRSP language also implies that a CP/CPS document cannot contain
subsections, which is incorrect.  Also, numbered subsections often appear
under RFC 3647 section headings. (Also, the CA/B Forum guidelines
themselves slightly depart from the RFC 3647 framework in a couple of
places - e.g. see https://github.com/cabforum/servercert/issues/513). This
email opens up discussion of GitHub Issue #263
<https://github.com/mozilla/pkipolicy/issues/263> "Clarify sentence
prohibiting blank sections that also contain no Subsections in CPs and CPSes
”.

Here in GitHub, lines 337 through 342
<https://github.com/BenWilson-Mozilla/pkipolicy/commit/974a527f567a6b7180f37aeb6b6c7f35a8b647d3>,
I am suggesting that we modify item 5 in Section 3.3 of the MRSP to read
something like:

5.  all CPs, CPSes, and combined CP/CPSes MUST be structured according to
the common outline set forth in section 6 of RFC 3647
<https://datatracker.ietf.org/doc/html/rfc3647#section-6>, as may be
amended by the CA/Browser Forum's TLS Baseline Requirements or its S/MIME
Baseline Requirements, and MUST:

       * include at least every section and subsection defined in section 6
of RFC 3647 <https://datatracker.ietf.org/doc/html/rfc3647#section-6>;

       * only use the words "No Stipulation" to mean that the particular
document imposes no requirements related to that section; and

       * contain no sections that are entirely blank, having no text or
subsections;

FWIW, the TLS Baseline Requirements currently state, "The Certificate
Policy and/or Certification Practice Statement MUST be structured in
accordance with RFC 3647 and MUST include all material required by RFC
3647."  Ballot SC-74 failed to pass in the CA/B Forum's Server Certificate
WG this past May
<https://lists.cabforum.org/pipermail/servercert-wg/2024-May/thread.html>
based on the discussions had there and because it appears that there were
unresolved questions, such as whether headers had to exactly match the text
and capitalization in RFC 3647. I think we can resolve some of those issues
here with a few minor edits to the proposed language.

Please provide any comments or suggestions you might have to improve this
proposed resolution of Issue #263.

Thanks,

Ben

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