Dear Rich,

Thank you for your question.

I think it would be advisable for a CA operator’s mass-revocation testing
plan to include an immediate notice to all customers whose certificates
were randomly selected because we would want to minimize disruption to
server operations while testing the CA’s ability to revoke and replace
certificates promptly.

That said, CAs should consider performing occasional tests that go beyond
providing pre-generated replacement certificates, in which subscribers
generate and submit new public keys. That would address the risks from a
widespread incident, like Heartbleed, where the potential compromise of
private keys necessitated key pair replacement. Preparing for such
scenarios ensures that subscribers will be able to quickly perform the
tasks of key pair generation, public key submission, and certificate
installation.

Much to discuss.

Thanks again,

Ben

On Wed, Dec 18, 2024 at 12:44 PM Rich Salz <[email protected]> wrote:

> As part of the discussions on this proposal, namely that CAs “maintain and
>> test mass revocation plans annually, including the revocation of 30
>> randomly chosen certificates within a 5-day period,” I’ve received a few
>> comments via private channels, and to ensure transparency and foster
>> discussion, I am sharing them here anonymously:
>>
> Would a CA be allowed to pre-notify customers whose certs were randomly
> selected and {pre/re}-issue them replacements?
>

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