I think the problem of delayed revocation is automatically solved once the 
proposed clarification by Mozilla (and other root store operators) clearly 
states that delayed revocation will unconditionally to removal from the trust 
store. Why invent a whole new mechanism when the same goal can be achieved much 
easier?

Kind regards & welcome to 2025
Roman

From: [email protected] <[email protected]> On 
Behalf Of Mike Shaver
Sent: Montag, 23. Dezember 2024 17:21
To: Rich Salz <[email protected]>
Cc: Matt Palmer <[email protected]>; [email protected]
Subject: Re: MRSP 3.0: Issue #276: Delayed Revocation

There are certainly CAs who could improve the overall state of the Web PKI by 
being more responsive to their commitments. We had an example this year of a CA 
sitting on revocation of invalid certs for more than a month because the vendor 
of their CA-management software said it would take that long to get the fix to 
their issuance (rather than directing their subscribers to get certs from 
another CA who could correctly issue certificates at that time—because it would 
cause inconvenience for the subscribers).

However, in many delayed revocation cases, it is indeed the Subscriber who 
needs to be more responsive to their (legally binding, as required per the BRs) 
commitments to tolerate prompt revocation. CAs in these circumstances are 
pressured to violate their covenants under the BRs and related policies, and 
defer revocation to accommodate Subscriber convenience (both immediate and 
historical, in the form of underinvestment in certificate management or 
automation). A random revocation test is really a test of the *Subscriber* 
population, and how they are influenced by the policies and (more importantly) 
actions of their chosen CA.

To emphasize, as a customer of the CA operating under the TLS BRs, you have 
legally agreed that the CA can blow away the cert in 24/120 hours and that you 
will tolerate that without unacceptable-to-the-world-and-the-web consequences. 
That legal commitment is often not reflected operationally, unfortunately, and 
the desired result of a random revocation audit is to smoke out those cases, 
and if that results in some operational distress for underprepared Subscribers, 
then hopefully their distress is helpful /pour encourager les autres/ as well 
as motivating the Subscribers in question to improve their operations.

IMO the random revocation should take exactly the same operational form as a 
real revocation under the 5-day clock: CA is notified that they need to revoke, 
identically to a CPR being filed, and then they inform the subscriber and the 
clock has started. When the clock expires, the certificate is revoked. I don't 
think that the process of issuing the replacement certificate is typically the 
long pole, and rather it's available as soon as the Subscriber asks for it. If 
the DCV is still in its validity period then the CA could proactively reissue 
at the point of the CPR arriving, if that proves to be a meaningful assistance 
to the Subscriber in replacing things.

Mike

On Thu, Dec 19, 2024 at 8:24 PM Rich Salz 
<[email protected]<mailto:[email protected]>> wrote:

On Thu, Dec 19, 2024, 6:59 PM Matt Palmer 
<[email protected]<mailto:[email protected]>> wrote:
Oh, I don't know... ransomware has been far more effective at improving
DR practices than several decades of education was.

An important difference is that I am a customer of the CA, and often paying for 
a service. I'm not paying you to DoS me.

In the venues where I mainly work( the ietf) we often say that revocation does 
not work on the web. Which part of the Web PKI needs to become more responsive? 
My hunch is that it is not the CAs.
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