Hi Ben, About " annual plan testing by revoking 30 randomly chosen certificates within a 5-day timeframe; and"... We understand that this mean that a CA will need to randomly revoke 30 certificates that most likely don't have other reason for being revoked than being randomly chosen and customers will just need to "happily" accept the situation... Harsh, but doable...
About "audit report submitted under section 3.1 SHALL include an attestation that the CA operator has met these mass revocation planning requirements", it must be considered that the attestation letters of Webtrust audit reports have a fixed format, so such addition would be added most likely as a "Other matters" section, that audits can take each differently. My question here would be if you think it's there any chance that these requirements become part of the TLS BRs instead of the Mozilla Policy, I see several benefits here: - Checking the mass-revocation plan would be integral part of the audit scope, so auditors don't need to figure out how to include it in the reports... it just needs to be added to the audit criteria. - The "inverse-lottery" thing could be added in the revocation timelines of the BR, so there's an entry in the 5-day deadline adding a new category "The certificate has been randomly chosen for revocation during an internal audit". This should facilitate the contractual language to add in the subscriber agreement. El domingo, 15 de diciembre de 2024 a las 21:51:43 UTC+1, Ben Wilson escribió: > All, > > The purpose of this email is to start discussion of Mozilla GitHub Issue > #276 <https://github.com/mozilla/pkipolicy/issues/276> ("Address Delayed > Revocation"). We would like to collect comments and feedback on a proposal > to address delayed certificate revocation from a Mozilla perspective. It > builds on prior discussions and feedback regarding delayed revocation, and > the proposal is meant to replace guidance currently provided on the > Mozilla CA wiki > <https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation>. > > Here is the comparison link for a proposed new section 6.1.3 in the MRSP: > > > https://github.com/mozilla/pkipolicy/compare/51b2f702accd54cb70d52081a9e814298433495b%E2%80%A6efa8ac40ac341fb813620938ef72328a53858038 > > > *Summary* > > Here are the highlights of the proposal: > > > - Revocation must occur promptly in compliance with the timelines set > in section 4.9.1 of the TLS Baseline Requirements (TLS BRs). Mozilla does > not grant exceptions to these timelines. > - New CA Obligations: > - Educate subscribers on revocation timelines and discourage > reliance on certificates in systems that cannot tolerate timely > revocation. > - Include contractual language requiring subscriber cooperation > with revocation timelines. > - Maintain and test mass revocation plans annually, including the > revocation of 30 randomly chosen certificates within a 5-day period. > - Beginning April 15, 2026, CA audit reports must attest to compliance > with the mass revocation planning requirements. > - Delayed revocation incidents must be reported per version 2.1 of the > CCADB's Incident Reporting Guidelines (as currently proposed > <https://github.com/mozilla/www.ccadb.org/pull/187>) > - Repeated delayed revocation incidents will result in heightened > scrutiny or sanctions, which may include root removal. > > *Background* > > Earlier this year, on this list, I proposed an Interim Policy to Address > Delayed Revocation > <https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/hXr43W3c4Gs/m/J1OAktIaAwAJ>. > > While the proposed interim policy provided clarity, it faced criticism > regarding implementation complexity, burden on subscribers and CAs, and the > feasibility of associated measures, such as transitioning delayed > revocation domains to 90-day certificates. Also, there were subsequent > proposals aimed at reducing certificate lifetimes and encouraging > automation. See e.g. https://github.com/cabforum/servercert/pull/553. > > This new proposal drops proposed measures such as domain-specific tracking > and subscriber attestations and instead focuses on subscriber education, mass > revocation preparedness, and robust incident reporting as the primary > mechanisms for improving agility and transparency regarding delayed > revocation. > > If adopted, the proposed MRSP § 6.1.3 would replace the current guidance > on delayed revocation in Mozilla’s wiki and ensure consistency with the > CCADB's Incident Reporting Guidelines. > > I welcome your feedback on this draft proposal. Please share your > thoughts, questions, or concerns to help us refine and improve it further. > > Thanks, > > Ben Wilson > > Mozilla Root Store > -- You received this message because you are subscribed to the Google Groups "[email protected]" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. To view this discussion visit https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/7f9a001e-bdc4-464d-ace6-58857d4dc97bn%40mozilla.org.
