To clarify, revocation within the prescribed timeline is a requirement of
the BRs for sure, but does Mozilla expect that there will never be a
violation of the BR revocation requirement? I don’t think that’s quite as
clear given the comments from the browsers. I do agree with Tim that such a
commitment should be a requirement though as it absolutely removes an
potential future ambiguity.



On Thu, Feb 6, 2025 at 6:35 PM Jeremy Rowley <rowley...@gmail.com> wrote:

> I think this statement from Ben makes it clear that the expectation is not
> that delayed revocation will never happen:
> https://bugzilla.mozilla.org/show_bug.cgi?id=1877388#c72
>
> You are right that I should not have made the statement alleging that
> sectigo might have ulterior motives. I apologize for that and retract that
> statement.
>
> I do think think it would be helpful to know which exact bugs Tim is
> objecting to closing and why? There are a couple that don’t have statements
> but some of them have been open for a year with non additional action items
> of note
>
>
> On Thu, Feb 6, 2025 at 6:12 PM Amir Omidi <a...@aaomidi.com> wrote:
>
>> > I think the public language did lead to confusion on what circumstances
>> delayed revocation could occur,
>>
>> Did it though? One of the expectations for CAs has been to watch and
>> monitor Bugzilla. If they had done so, I don't think this confusion would
>> exist.
>>
>> > If we want each CA to say "We will never delay revocation" again, we
>> could say that must be stated in the closing. As that is expressly not
>> stated as a requirement, I'm baffled on what more most of the bugs need
>> before closing
>>
>> What do you mean that is not a requirement? As far as I know practically
>> all the root programs and the BRs are clear about this being a requirement.
>>
>> > Keeping a bug open just to make a CA look bad for Sectigo seems like an
>> improper purpose for having a bug reporting mechanism.
>> > The value to Sectigo and the Sectigo podcast is pretty obvious
>>
>> These statements do not belong in this mailing list.
>>
>>
>> On Thu, Feb 6, 2025 at 4:58 PM Jeremy Rowley <rowley...@gmail.com> wrote:
>>
>>> Perhaps it would be better to look at each delayed revocation bug:
>>>
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1945389 - No comments so
>>> far
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1943528 - Entrust was
>>> distrusted so no need to keep it open
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1942879 - Issue identified
>>> and the delay was unintentional
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1942877 - Issued
>>> identified and delay was unintentional
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1922572 - No comments
>>> after KIRs explanation
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1916478 - Delay appears
>>> unintentional and was an operational issue
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1910805 - Delay was
>>> explained in more detail than other bugs
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1903066 - Comment 6
>>> acknowledges the delay was wrong
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1898848 - Entrust is
>>> distrusted
>>>  https://bugzilla.mozilla.org/show_bug.cgi?id=1898848 - Acknowleded
>>> that it was a mistake to delay yet Tim keeps pushing
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1891331 - Netlock talks
>>> about the EU difficulties in revocation
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1889062 - Acknowledges
>>> that it was against the BRs to delay
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1888882 - Comment 28
>>> pretty much states that will ensure awareness of teh 5 day requirement
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1887888 - This one never
>>> answered the question of what they will do going forward.
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1887110 - Acknowledges it
>>> was a violation
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1886665 - States that htey
>>> will not delay revocation
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1886532 - Entrust was
>>> distrusted
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1885568 - Remediation
>>> provided
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1872738 - Remediation
>>> provided
>>>
>>> Given the bugs, the lengthy discussion on the bugs, and the revised
>>> language in the Mozilla revocation expectation document, what is the value
>>> to the community in keeping these open? The value to Sectigo and the
>>> Sectigo podcast is pretty obvious, but why would Mozilla or the Mozilla
>>> community want to keep going on these items? If there is a clear ask on
>>> what should be done, what is it?
>>>
>>> If we want each CA to say "We will never delay revocation" again, we
>>> could say that must be stated in the closing. As that is expressly not
>>> stated as a requirement, I'm baffled on what more most of the bugs need
>>> before closing.
>>>
>>>
>>> On Thu, Feb 6, 2025 at 2:32 PM Jeremy Rowley <rowley...@gmail.com>
>>> wrote:
>>>
>>>> I disagree. I think the language was unclear before, and, based on my
>>>> previous work. I think the public language did lead to confusion on what
>>>> circumstances delayed revocation could occur, but I have not seen anyone
>>>> state that the delay was in compliance with the BRs. This seems like a
>>>> misrepresentation of most of the CAs, and a misrepresentation that is
>>>> particular sus given that it is coming from a competitor to the other CAs.
>>>> I think you should close the current bugs given that the language has
>>>> changed, even if the expectations around delayed revocation remain
>>>> constant.
>>>>
>>>> Keeping a bug open just to make a CA look bad for Sectigo seems like an
>>>> improper purpose for having a bug reporting mechanism. Isn't the purpose to
>>>> learn why it happened and rectify the issue? Seems like this has happened
>>>> on all of the bugs I've seen and Mozilla policy has become better for it.
>>>>
>>>>
>>>>
>>>> On Thu, Feb 6, 2025 at 2:18 PM Tim Callan <ptimcal...@gmail.com> wrote:
>>>>
>>>>> Ben,
>>>>>
>>>>> You may see from my recent posts on a few of these individual bugs
>>>>> that at least some of these incidents in my opinion aren’t ready to close.
>>>>> There has been and continues to be a problem with CAs failing to recognize
>>>>> that BR-mandated revocation deadlines are not theirs to take or leave, and
>>>>> we still have CAs, sometimes nearly a year later, who have not 
>>>>> acknowledged
>>>>> this fact nor taken steps to fix their errors.  I appreciate your response
>>>>> to one of my recent posts in which you say that a hard commitment to never
>>>>> delay revocation is too much.  Though I do not agree, I understand your
>>>>> viewpoint and am taking your guidance.
>>>>>
>>>>> That said, my recollection is that some of these CAs have simply never
>>>>> publicly accepted any culpability nor made an earnest show of changing
>>>>> their priorities.  I put it to you that a CA who refuses to accept
>>>>> responsibility for its free choice to ignore the BRs and has no expressed
>>>>> intention to change its decision making has not remediated the problem. I
>>>>> believe such a bug should remain open until the message sinks in.
>>>>>
>>>>> If you concur on this last point, then I request you leave these bugs
>>>>> open just a little longer so the community has a chance to review them and
>>>>> weigh in on which are ready to close and which are not.  I don’t imagine
>>>>> this requires a great deal of time, but I don’t see it getting done by
>>>>> tomorrow either.
>>>>>
>>>>> Cheers,
>>>>>
>>>>> -tlc
>>>>>
>>>>> On Sunday, February 2, 2025 at 2:25:39 PM UTC-5 Ben Wilson wrote:
>>>>>
>>>>>> All,
>>>>>>
>>>>>> I am considering closing the following delayed revocation Bugzilla
>>>>>> incidents later this week (Friday, 7-Feb-2025), as listed in meta Bug
>>>>>> 1911183 <https://bugzilla.mozilla.org/show_bug.cgi?id=1911183>:
>>>>>>
>>>>>> 1872738 <https://bugzilla.mozilla.org/show_bug.cgi?id=1872738>,
>>>>>> 1877388 <https://bugzilla.mozilla.org/show_bug.cgi?id=1877388>,
>>>>>> 1884568 <https://bugzilla.mozilla.org/show_bug.cgi?id=1884568>,
>>>>>> 1885568 <https://bugzilla.mozilla.org/show_bug.cgi?id=1885568>,
>>>>>> 1886110 <https://bugzilla.mozilla.org/show_bug.cgi?id=1886110>,
>>>>>> 1886532 <https://bugzilla.mozilla.org/show_bug.cgi?id=1886532>,
>>>>>> 1886665 <https://bugzilla.mozilla.org/show_bug.cgi?id=1886665>,
>>>>>> 1887110 <https://bugzilla.mozilla.org/show_bug.cgi?id=1887110>,
>>>>>> 1887888 <https://bugzilla.mozilla.org/show_bug.cgi?id=1887888>,
>>>>>> 1888882 <https://bugzilla.mozilla.org/show_bug.cgi?id=1888882>,
>>>>>> 1889062 <https://bugzilla.mozilla.org/show_bug.cgi?id=1889062>,
>>>>>> 1890685 <https://bugzilla.mozilla.org/show_bug.cgi?id=1890685>,
>>>>>> 1891331 <https://bugzilla.mozilla.org/show_bug.cgi?id=1891331>,
>>>>>> 1892419 <https://bugzilla.mozilla.org/show_bug.cgi?id=1892419>,
>>>>>> 1896053 <https://bugzilla.mozilla.org/show_bug.cgi?id=1896053>,
>>>>>> 1896553 <https://bugzilla.mozilla.org/show_bug.cgi?id=1896553>,
>>>>>> 1898848 <https://bugzilla.mozilla.org/show_bug.cgi?id=1898848>,
>>>>>> 1903066 <https://bugzilla.mozilla.org/show_bug.cgi?id=1903066>,
>>>>>> 1910805 <https://bugzilla.mozilla.org/show_bug.cgi?id=1910805>,
>>>>>> 1916478 <https://bugzilla.mozilla.org/show_bug.cgi?id=1916478>, and
>>>>>> 1924385 <https://bugzilla.mozilla.org/show_bug.cgi?id=1924385>,
>>>>>>
>>>>>> *provided that the CA operator has completed its stated Action Items
>>>>>> and filed a Closure Summary*.
>>>>>>
>>>>>> My reasoning is as follows:
>>>>>>
>>>>>> I kept these bugs open while we navigated towards a solution for
>>>>>> handling delayed revocations going forward. I believe that the new 
>>>>>> language
>>>>>> in Mozilla Root Store Policy (MRSP) 3.0, effective March 1, 2025,
>>>>>> introduces significant measures to improve compliance with revocation
>>>>>> requirements and enhance delayed revocation incident reporting.
>>>>>>
>>>>>> Under MRSP section 6.1.3, CA operators will be explicitly required to
>>>>>> engage in proactive subscriber communication, more specific contractual
>>>>>> provisions, and mass revocation preparedness to ensure timely certificate
>>>>>> revocation. Additionally, CAs must undergo third-party assessments to
>>>>>> validate their readiness for large-scale revocations and that they have
>>>>>> documented the outcomes of the testing of their mass revocation plans.
>>>>>>
>>>>>> MRSP section 2.4 incorporates the updated incident reporting
>>>>>> requirements of the CCADB, and mandates that CAs provide detailed and
>>>>>> substantiated justifications in incident reports, explaining delays and
>>>>>> impacts on third parties. It notes that Mozilla does not have any
>>>>>> exceptions for delayed revocation, and that repeated unjustified delays
>>>>>> will result in heightened scrutiny and potential removal from the Mozilla
>>>>>> Root Store.
>>>>>>
>>>>>> Also, MRSP section 7.1 will require that new TLS-issuing root
>>>>>> certificates have at least the ability for automated domain control
>>>>>> validation, certificate issuance, and retrieval. This ensures that
>>>>>> certificate management processes are efficient, scalable, and less prone 
>>>>>> to
>>>>>> human error, aligning with modern security best practices.
>>>>>>
>>>>>> CAs and stakeholders should recognize these changes only as first,
>>>>>> yet important, steps in addressing delayed revocation and reporting.
>>>>>>
>>>>>> Thoughts?
>>>>>>
>>>>>> Thanks,
>>>>>>
>>>>>> Ben
>>>>>>
>>>>>> --
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