During the year 2005 the Mozilla CA policy was defined, mostly as a 
result of CAcert's request to have their CA root shipped with NSS and I 
remember the initial drafts, which were published at Franks personal web 
site very good. This was a process I closely followed from the sidelines 
since it had quite some relevance for the StartCom CA which I just 
founded back then and its operations I still directly oversee today.

The Mozilla CA policy was the first published policy by a software 
vendor which included some detailed requirements, specially ones seemed 
to be important at that time. Other vendors had very vague requirements, 
mainly that of a WebTrust audit, some had none. And in that respect 
Mozilla lead the way for all other vendors, as today Microsoft and even 
Opera have policies with specific requirements.

One of the more important aspects of the new Mozilla CA policy was the 
definition of alternative auditors beyond WebTrust accredited ones and 
effectively removing the WebTrust tax for CAs (Also a concession to 
CAcert, which however also poses some risks). The accepted criterion 
remained the same ones which were and still are considered industry 
standard. Additionally some specific requirements and some 
recommendations were included. Thanks to Frank's pragmatism and 
willingness to facilitate the inclusion of CAcert, StartCom took this 
opportunity with both hands by closely following the requirements and 
recommendations of the evolving policy.

During the years 2006-2007 the EV criteria evolved with the support of 
some major CAs and browser vendors, which Mozilla eventually adopted and 
voted in favor. There are perhaps multiple reasons for the creation of 
the EV criteria and each party is supporting it for its own reasons.

Since the creation of Firefox, the handling of SSL certificates by the 
various Mozilla softwares (browsers, suites, mail etc) had hardly 
changed and remained mostly static. But the development for Firefox 3 
introduced suddenly many changes, most likely due to the arrival of the 
EV criteria, but also for the desire to improve security and online 
experience of its users. Firefox 3 looks differently at SSL errors and 
the UI changed in many ways (not to mention many improvements in the NSS 
library itself). With very little tolerance and rigorous checking of SSL 
secured sites, Firefox 3 is going to be a great improvement after years 
of stagnation.

But our Mozilla policy hasn't kept pace with the developments of the CA 
industry and that of its browser, except the addition of the EV 
criteria. Effectively the Mozilla CA policy remained static since its 
introduction, which is perhaps desirable (that a policy doesn't change 
every here and now). On the other hand, since its introduction, some CA 
practices by some CAs have gone dangerously low and more and more CAs 
knock at Mozilla's door and request to be included and shipped with NSS 
(the later is just fine if there weren't sometimes for the problems and 
some dubious practices involved).

Today I feel, that the Mozilla CA policy and the inclusion process isn't 
fully up to its task for various reasons. Specially also because of the 
advancing of the software I feel that the policy hasn't kept pace. 
What's the use of effectively blocking access to a web site which is 
perhaps wrongly configured, when on the other hand CAs are given a free 
hand to do as they wish?

During my short involvement with this team and specially during the last 
ten month I've encountered countless policies, practice statements and 
implementations for which the Mozilla policy doesn't provide answers, 
but which were nevertheless risky, to say the least. Additionally I have 
the feeling that there is flaw in the "review" system, because if it 
wasn't for me and the public comment period, _we'd have today CAs in NSS 
which weren't audited at all and which wouldn't have any requirements 
whatsoever placed upon them_ (like the bare minimum of domain/email 
validation).

And because of that I'm asking the community, this team and the Mozilla 
Foundation, what is it that we want! There is no road map in place which 
would provide some guidance. There is no clear vision about how and what 
we should do (except that there is a policy and we accept requests on an 
ongoing basis). And I'm not even sure that anybody besides me sees any 
need to introduce changes and improvements at all. Not surprisingly, I 
don't see many others involved really. Instead the amount of requests 
for inclusion has dramatically increased since the introduction of the 
policy, but the responsibility and decision remained placed upon one 
person only (First Frank, then Gerv and now Frank again). During all 
that time, the only CA which has drawn some fire during the comment 
period was StartCom, which in itself might be understandable because of 
StartCom's position and unique approach (CAcert + some commercial CAs 
weren't all that happy I guess).

But haven't it been for my involvement during the last time, there 
wouldn't be any second opinions and no second reviews of CAs whatsoever. 
This in itself is an unhealthy situation, not because Frank (and Gerv) 
do a bad job, but because people do make mistakes and tend to look at 
things differently. In the absence of better definitions (and 
recommendations) by the Mozilla policy, many times a decision must be 
taken on different issues based on...one persons point of view. Updates 
to the Mozilla policy are delayed indefinitely, no working group exists, 
not many consultations are taking place (if at all). And for me 
personally, willing to invest time and effort, but instead of 
contributing my expertise and experience I'm rather playing an 
opposition I don't want to play really, it has been somewhat unsatisfying.

So what is it that we (and the Mozilla foundation) want? Is it correct 
the way we handle things here (basically Frank/Gerv proposing inclusion, 
Eddy reviewing and sometimes objecting, if not Eddy, nobody really will) 
or is there a better approach? Is it correct that decisions for updates 
to the CA policy are converted to recommendations which have no effect 
whatsoever when actually using them as an argument against inclusion of 
a CA (or request for change of said practice by the CA)? Shouldn't a 
group of experts review CAs and make decisions based on more than one 
persons opinion? Shouldn't a working group actively review proposed 
changes to the Mozilla CA policy and make decisions? So what is it that 
we want? We have an updated UI and improved NSS for FF3, but we don't 
have a really good inclusion process for CAs (note that the comment 
period is really unique and helpful, but it is missing the point if 
there is no real community actively reviewing the bits and bytes of the 
CP/CPS and other material of the CAs in question. Based on the comments 
I've seen during the last two years, serious work is basically 
non-existent).

I came to the decision to write this mail and raise these questions, 
because I felt it somewhat pointless to provide my expertise upon the 
mail from Frank with the title "Audit requirements for government CAs", 
without defining what is it that this community and the Mozilla 
foundation wants before hand. I have no fun in playing an opposition to 
Frank just for the sake of it - and the last three CAs about which I 
raised some objections and the resulting discussions have left myself 
with questions, for which I feel I need some answers.

What do you think? Is there room for such a definition (about what we 
really want)? Is there a need for it at all or is everything fine? Do we 
need to improve and change the ways things are handled currently? Should 
an experts group make the decisions for inclusion or should it remain as 
is? Should a working group be created for dealing with aspects of the 
Mozilla CA policy? Is the way we deal today sustainable over time? Other 
suggestions?

-- 
Regards 
 
Signer:         Eddy Nigg, StartCom Ltd. <http://www.startcom.org>
Jabber:         [EMAIL PROTECTED] <xmpp:[EMAIL PROTECTED]>
Blog:   Join the Revolution! <http://blog.startcom.org>
Phone:          +1.213.341.0390
 

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