On Thu, Feb 19, 2026, 11:52 AM 'Gurleen Grewal' via
[email protected] <[email protected]> wrote:

> Thanks, Aaron, for initiating this discussion. You are correct that the
> relevant requirement we planned to cite in our recent incident
> <https://bugzilla.mozilla.org/show_bug.cgi?id=2017747> is from section
> 3.2.2.4 (and also section 3.2.2.5 for IP validation). While we are working
> on a detailed report, we’ll offer some clarifications and thoughts relevant
> to this thread:
>
> Our interpretation of BR Section 3.2.2.4 was mostly in line with Aaron’s -
> that the log should reflect the BR version in effect at the time of
> validation. Our incident report was filed because we discovered that the BR
> versions we were recording were outdated.
>
> With the interpretation that Dexter gave, our situation might not have
> been considered a reportable incident at all.
>
> We agree with the concerns raised, particularly under Aaron's
> interpretation, that achieving instantaneous compliance the moment a new BR
> version becomes effective is operationally very challenging.
>
> On Ryan’s interpretation - the issue is that the analysis and any
> necessary code changes to comply with the substance of new BR requirements
> must logically be completed before the effective date. However, the
> separate act of changing the version number that is logged can only occur
> at or after the new version becomes effective.
>

I don't think that's correct. Your code will through some mechanism change
the validation behavior at some time t. At that time it can change the
logging as well to match.

>
> This seems to imply that the mechanism for updating the logged BR version
> string must be decoupled from other code rollouts related to substantive BR
> changes. To meet a strict interpretation, a CA would likely need an
> independent process to monitor for newly effective BR versions and update a
> configuration value for the logging system, separate from regular code
> deployment cycles. This is further complicated by typical rollout schedules
> (e.g., weekly deployments) and potential production freezes, which can
> easily introduce delays.
>
> Building and maintaining a system solely to ensure the logged BR version
> string flips at the precise moment of effectiveness, detached from the
> rollout of any actual logic changes, feels like it could become a
> significant overhead. In our day-to-day operations, we have not felt the
> need to query or filter validation data based on the BR version in force.
>
> We are very interested in the community's thoughts and suggestions on:
>
>
>    1.
>
>    How the Baseline Requirements could be clarified regarding the
>    expectations for logging the BR version, especially concerning the timing
>    of updates. Is there an acceptable propagation delay?
>    2.
>
>    As Ben said: the forum has often chosen to obsolete prior validation
>    methods and introduce new method numbers when changes are made. Based on
>    this, should we consider dropping the requirement of keeping a record of
>    the version, and simply rely on the creation timestamp of the log entry
>    since CAs must always apply the current BR version anyway?
>    3.
>
>    A CA is expected to conform to its Certificate Policy and
>    Certification Practice Statements, which are versioned independently of the
>    BRs; would it make more sense to version validations with the CP/CPS
>    versions in force instead of the BR versions?
>
>
> We believe that the goal is to ensure audits can trace the rules applied,
> and we hope to find a solution that is both effective and implementable
> without excessive burden.
>
> Thanks,
> Gurleen Grewal/Google Trust Services
> On Thursday, February 19, 2026 at 10:02:30 AM UTC-8 Ben Wilson wrote:
>
>> Hi All,
>>
>> I would like to add a brief perspective to the discussion regarding
>> Section 3.2.2.4 and the obligation to record the relevant BR version used
>> for domain validation.
>>
>> My recollection of the original intent behind this provision was that the
>> validation method number and the BR version number were meant to function
>> together for identification of the validation method used. A validation
>> method might evolve slightly while retaining the same method identifier,
>> and the BR version number would provide additional precision about the
>> exact rule set used for validation. In that sense, the BR version number
>> was intended to complement the method number by identifying the governing
>> text associated with that implementation. And it wasn't thought that CAs
>> would revise domain validation code and logging processes every time a new
>> version of the BRs was adopted.
>>
>> In practice, however, the Forum has often chosen to obsolete prior
>> validation methods and introduce new method numbers when changes are made.
>> As a result, the method identifier itself now typically captures the
>> substantive change. That evolution in drafting practice arguably reduces
>> the independent utility of the BR version number as a proxy for
>> method-level differences.
>>
>> This is distinct from the MRSP obligation to conform to the latest
>> version of the TLS BRs. If a new version introduces substantive changes to
>> validation requirements, both implementation and recorded version must
>> reflect those changes. That is not in dispute.
>>
>> The narrower question is whether Section 3.2.2.4 requires version
>> recording to track the publication state of the consolidated BR document at
>> a given moment in time, even where no changes were made to the applicable
>> validation method and no implementation changes occurred. If ambiguity
>> exists on that point, it may be useful to clarify the language
>> prospectively to ensure auditability and consistent interpretation.
>>
>> I would be open to filing an MRSP GitHub issue to tighten our
>> interpretation of Section 3.2.2.4 and, if appropriate, revise the MRSP
>> language to ensure operational expectations are precise. The goal should be
>> accurate record-keeping tied to governing validation logic, without
>> creating unnecessary implementation churn where no substantive requirements
>> have changed.
>>
>> Best regards,
>> Ben
>>
>> On Thu, Feb 19, 2026 at 10:41 AM Ryan Hurst <[email protected]> wrote:
>>
>>> Hi all,
>>>
>>> I think the operative word in Section 3.2.2.4 is "*used*." The
>>> requirement is to record which BR version was used to validate every
>>> domain, not which version happened to be current when the clock ran.
>>>
>>> *"Used" is an operational term*. It refers to the validation procedure
>>> actually applied. If a CA performed validation under rules that haven't
>>> changed between v2.2.2 and v2.2.3, it didn't use v2.2.3. It used the
>>> version whose logic it implemented.
>>>
>>> The MRSP conformance obligation and the Section 3.2.2.4 recording
>>> obligation are distinct. Conformance to the latest version means deploying
>>> its logic, and the log should reflect what logic ran. A CA that logs the
>>> new version before deploying its logic is recording what it was supposed to
>>> conform to, not what actually ran.
>>>
>>> The corollary matters, though. A CA whose validation code hasn't been
>>> updated to implement a new version cannot truthfully log that version.
>>> Logging the current version when the code hasn't caught up is a false
>>> record. It records what the CA was supposed to conform to, not what logic
>>> actually ran.
>>>
>>> This interpretation is verifiable by an auditor, assuming a functioning
>>> change management regime is in place. A CA whose stamps are inconsistent
>>> with its deployment history has a substantive problem, not a record-keeping
>>> one.
>>>
>>> Where I'd push back on Dexter's framing is on different grounds.
>>> Recording an older version and arguing the validation was permissible under
>>> both isn't the same thing as recording the version you actually
>>> implemented. The log should be a statement of fact about what governed the
>>> issuance, not a retroactive argument about compatibility with both versions.
>>>
>>> The three incidents Aaron cited resolve differently under this reading.
>>> If those CAs' validation logic hadn't been updated, that's both a
>>> substantive compliance failure under MRSP and a recording failure, two
>>> distinct findings. If the logic was current but the version stamp wasn't,
>>> that's a record-keeping error of a different character, and one the audit
>>> record can help distinguish.
>>>
>>> The operational gap Aaron describes largely disappears once "used" is
>>> understood as referring to deployed logic rather than clock time. The
>>> remaining ambiguity around effective dates and timezones is a CA/BF
>>> drafting problem worth fixing, and standardizing on UTC would largely close
>>> it.
>>>
>>> That said, a recording failure that stems solely from timezone ambiguity
>>> in the effective date, where the underlying validation logic was current,
>>> seems the kind of thing that should be a note in an audit and not something
>>> that would cause someone to do a incident report or lose their Webtrust
>>> seal.
>>>
>>> Thanks, Ryan
>>>
>>> On Wednesday, February 18, 2026 at 4:18:27 PM UTC-8 Dexter Castor
>>> Döpping wrote:
>>>
>>>> Hi all,
>>>>
>>>> Regarding question #2:
>>>>
>>>> A CA must conform to the latest version version of the BRs, but I don't
>>>> see anywhere that they aren't allowed to use the DV rules of older BRs and
>>>> record this as the BR version. In this case the CA must make sure that what
>>>> they're doing is allowed in both the old and new version of the BRs.
>>>>
>>>> Imagine version 1 allows CAs to do (A,B,*C*) and version 2 allows (A,B,
>>>> *D*).
>>>>
>>>> If the records show that version 1 was used after version 2 was
>>>> released, then they must not have done (C) or (D), but (A,B) would be fine.
>>>>
>>>> If the CA wants to start doing (D), then the CA system must be updated
>>>> to record that version 2 of the BRs was used for DV.
>>>>
>>>> That's my interpretation at least.
>>>>
>>>> CA's should be aware of upcoming changes, and breaking changes often go
>>>> into effect at a later date. E.g., (C) isn't outright removed, rather the
>>>> BRs would say "Effective [future date] a CA MUST NOT do (C)". So I don't
>>>> think that following a common subset of DV rules after a new BR release
>>>> would be challenging.
>>>>
>>>> Technically a CA could stay on an ancient version of the BRs for DV
>>>> requirements, it just wouldn't be a good idea because it becomes harder and
>>>> harder to keep track of the common subset of requirements, and at some
>>>> point it could even become impossible. E.g., version 1 says a CA MUST do
>>>> (X) and version 101 says a CA MUST NOT do (X). So recording an old version
>>>> of the BRs unnecessarily long would be a bad practice and isn't in the CA's
>>>> interests.
>>>>
>>>> Regards,
>>>> Dexter
>>>>
>>>> On 2026-02-19 00.30, 'Aaron Gable' via [email protected] wrote:
>>>>
>>>> I'd like to agree, but I'm not sure that's the case. The Mozilla Root
>>>> Store Policy
>>>> <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>
>>>>  says
>>>> that CAs "MUST conform to the *latest version* of the CA/Browser
>>>> Forum's TLS BRs" (emphasis mine). Performing validation in line with an
>>>> older version of the BRs would be a violation of the MRSP, even if there is
>>>> no difference for that particular validation method.
>>>>
>>>> Aaron
>>>>
>>>> On Wed, Feb 18, 2026 at 3:26 PM Watson Ladd <[email protected]> wrote:
>>>>
>>>>> Dear Aaron,
>>>>>
>>>>> I think this is premised on a misunderstanding of what I would think
>>>>> the requirements are. The CA must record what version of the BRs was
>>>>> used for validation. Let's say we go from version 1 to version 2 to
>>>>> version 3. If Version 1 and version 2 don't contain any differences
>>>>> relating to DV, then there is no problem. If 2 to 3 does, than the
>>>>> requirement is that when the CA implements and deploys the new logic,
>>>>> it records that it did so. The publication process of CABforum
>>>>> documentation isn't I think linked to that transition.
>>>>>
>>>>> Sincerely,
>>>>> Watson
>>>>>
>>>>> On Wed, Feb 18, 2026 at 3:21 PM 'Aaron Gable' via
>>>>> [email protected] <[email protected]>
>>>>> wrote:
>>>>> >
>>>>> > Hi all,
>>>>> >
>>>>> > I'd like to present two pieces of relevant context, and then ask a
>>>>> few questions. Although this does somewhat concern CA/BF processes and
>>>>> policies, I am sending this message to MDSP because it concerns a question
>>>>> of whether a particular action is a violation of the requirements, a topic
>>>>> upon which the CA/BF itself does not pass judgement.
>>>>> >
>>>>> > Context #1:
>>>>> >
>>>>> > In the past few weeks, three Bugzilla incidents have been opened
>>>>> regarding recording the current version of the Baseline Requirements in
>>>>> validation event audit logs:
>>>>> >
>>>>> > - Chunghwa Telecom: Domain validation records without the TLS BR
>>>>> version
>>>>> > - iTrusChina: Domain validation records without the TLS BR version
>>>>> > - Google Trust Services: Outdated BR version in some validation
>>>>> records
>>>>> >
>>>>> > The relevant requirement cited in the first two incidents (and I
>>>>> suspect likely to be cited in the third incident's full report) is from
>>>>> Section 3.2.2.4:
>>>>> >
>>>>> > > CAs SHALL maintain a record of which domain validation method,
>>>>> including relevant BR version number, they used to validate every domain.
>>>>> >
>>>>> > Context #2:
>>>>> >
>>>>> > The CA/BF has recently published several new versions of the
>>>>> Baseline Requirements. For example:
>>>>> >
>>>>> > - SC-094, with an Effective Date of 2026-02-16, was merged at
>>>>> 2026-02-16 21:06 UTC, and v2.2.3 was announced on the mailing list at
>>>>> 2026-02-16 21:13 UTC
>>>>> > - SC-096, with an Effective Date of 2026-02-17, was merged at
>>>>> 2026-02-17 20:30 UTC, and v2.2.4 was announced on the mailing list at
>>>>> 2026-02-17 20:36 UTC
>>>>> > - Both new versions were merged to the website repo at 2026-02-18
>>>>> 03:40 UTC, and the website itself was updated about four minutes later
>>>>> >
>>>>> > Questions:
>>>>> >
>>>>> > 1. At what time does a new BRs version become effective? The BRs
>>>>> themselves only give a date, not including a time nor a time zone. But the
>>>>> new version of the BRs is often not published until some portion of the 
>>>>> way
>>>>> through that day (or the previous day, or the next day, depending on time
>>>>> zones). Does a new version become effective at midnight UTC on the date
>>>>> given as the Effective Date within the document? Or when merged into the
>>>>> `main` branch of the github repo? When sent to the mailing list? When
>>>>> published to the website?
>>>>> >
>>>>> > 2. Let's assume for the moment that a new BRs version becomes
>>>>> effective when the email announcing it is sent to the mailing list. 
>>>>> Suppose
>>>>> a validation is performed one second after that email is sent, and the CA
>>>>> records the previous Baseline Requirements version number. Is that a
>>>>> violation of the requirement from Section 3.2.2.4? If yes, is there a
>>>>> reasonable way for a CA to anticipate publication of a new BRs version and
>>>>> cease all validation activities until it is actually published?
>>>>> >
>>>>> > Thank you for your time and discussion,
>>>>> > Aaron
>>>>> >
>>>>> > --
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>>>>> .
>>>>>
>>>>>
>>>>>
>>>>> --
>>>>> Astra mortemque praestare gradatim
>>>>>
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