Have we learnt nothing from Crazy Eddie? If you don't go up to the shelves
and count boxes, you aren't going to catch the fraud.


Astra mortemque praestare gradatim

On Mon, Feb 23, 2026 at 12:40 PM Ryan Hurst <[email protected]> wrote:
>
> The pressure in this thread is the same pressure that shows up repeatedly
in this ecosystem, reduce specificity in the name of operational
efficiency. Sometimes that pressure is legitimate. Sometimes the
requirement being relaxed is genuinely redundant. But the cumulative effect
of that pattern will be an environment where it will be progressively
harder to audit and a CA ecosystem that is progressively less accountable.
>
> That would not matter much if our audit regime were more robust than it
is today.  WebTrust and ETSI audits are point-in-time,
documentation-focused engagements that rarely involve deep technical
inspection of deployed systems. Root programs have had to step in
repeatedly because clean audit opinions were not reflecting operational
reality. That is not a criticism of auditors individually, it is a
structural problem.
>
> Ultimately, this is a decision root programs will have to make. Optimize
for CA operational flexibility and trust that CAs will make the right call,
or optimize for accountability by preserving the signals that give auditors
something concrete to work with. Removing requirements like this one makes
the first choice easier. It makes the second choice harder. We should at
least be clear that is the tradeoff we are making.
>
> Ryan
>
>
> On Mon, Feb 23, 2026 at 11:21 AM 'Trevoli Ponds-White' via
[email protected] <[email protected]> wrote:
>>
>> I agree Aaron, I also want to make sure we are focusing on operational
and security outcomes. Not audit optimization driven ones. This is why I
proposed we update that requirement to be more clear. I’m not also opposed
to removing it given that we are now being more aggressive at deprecating
methods. If I recall another reason we wanted to add that was so that we
would have the ability to understand how much which validation methods are
used to help understand impact of deprecation. Its not actually clear to me
how you could reasonably issue a cert without knowing it’s validation
method so requiring this may be moot.
>>
>>
>>
>> On Monday, February 23, 2026 at 10:35:00 AM UTC-8 Aaron Gable wrote:
>>>
>>> On Mon, Feb 23, 2026 at 9:42 AM Ryan Hurst <[email protected]> wrote:
>>>>
>>>> The timestamp consistency argument makes me uncomfortable. Applied
broadly, it would justify removing every discrete data point the BRs
require CAs to log, since auditors can always work backwards from a
timestamp and a changelog.
>>>
>>> Sure, but I'm not talking about applying this broadly, and I'm not
talking about reducing the CA's requirement to log what they do. I'm
talking specifically about recording a specific piece of information which
is at best redundant and at worst contradictory. That objection is to a
strawman, not to the argument I'm making.
>>>
>>> We have a direct statement from a root program representative above
saying that the point of this requirement is outcome-oriented: "for each
validation event, the CA must be able to determine which validation method
and which BR version governed that validation.". That's possible entirely
with timestamps, just as it is possible to map issuance events to BR
versions solely using timestamps.
>>>>
>>>> On the DNSSEC example, a version stamp gives an auditor a bounded and
deterministic starting point. They know exactly which two document versions
to compare and can verify the CA's behavior against that specific set of
changes.
>>>
>>> Why are they comparing documents at all? That's more work! They only
need to be looking at one document: the one that was in force at the time
of the validation.
>>>>
>>>> Without it, they first have to determine which version was in effect
at the moment of validation, which is exactly the problem this thread
started with: effective dates without times, timezone ambiguity,
publication lag.
>>>
>>> They have to make that determination anyway, which yes is hard and we
should fix that, but providing a BR version in the log line does not make
their job any easier.
>>>
>>> Aaron
>>
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