Dear ChyaHung Tsai,
Could these alerts be due to the cross-signing of the roots by the TWCA 
Global Root CA? 
In the CCADB, both of these roots also appear as subordinate CAs because 
they are signed by the TWCA Global Root CA (it doesn't matter that they are 
called "roots"), so they would inherit the trust of that root, which has 
both trust bits indicated. I think that might be the reasoning.
I'm not sure about the expiring CRL you mention.
Ben

On Wednesday, March 5, 2025 at 6:30:51 PM UTC-7 [email protected] wrote:

Hi Rob,

Thank you for providing a summary of the S/MIME BR Audit disclosure status. 
On behalf of TWCA, I would like to raise a few questions regarding the 
alerts on https://crt.sh/mozilla-disclosures:

   1. *[Root] TWCA CYBER Root CA* is a TLS-only certificate hierarchy. In 
   CCADB, the trust bits are only set for "website," but it appears as both 
   "Server" and "Email" in the report. Could you clarify why?
   2. Following the previous point, since this Root CA does not issue 
   S/MIME certificates, it should not require an S/MIME Audit. Is this 
   assumption correct?
   3. *[Root] TWCA Global Root CA G2* does not have TLS issuance 
   capabilities. In CCADB, the trust bits are only set for "email," but it is 
   displayed as both "Server" and "Email" in the report. Could you clarify why?
   4. Following the previous point, since this Root CA does not issue TLS 
   certificates, it should not require a BR or EV Audit. Is this assumption 
   correct?
   5. *TWCA Global Root CA G2* has indeed cross-certified  by *TWCA Global 
   Root CA*. The cross-certificate (D53BF4968A7DB3C8...) has "Audits Same 
   as Parent" checked,. Could you confirm?
   6. We have noticed warnings regarding *CRL expiration*, but after 
   verifying the CRLs downloaded from the CDP, they all appear to be 
   valid. Could you confirm?
   7. We observed that in the *Subject CN field*, only TWCA includes the 
   word "Root," while other CAs only list Intermediate CAs. Is this a 
   coincidence, or does TWCA need to make any adjustments?

If we have misunderstood the information presented on the disclosure page 
or misinterpreted any CCADB attributes, please let us know. If this is 
confirmed as an incident, we will disclose it on Bugzilla following the 
latest CCADB incident reporting template.

Thank you.

Best regards,
ChyaHung Tsai
TWCA


Rob Stradling 在 2025年3月6日 星期四清晨5:03:38 [UTC+8] 的信中寫道:

Per the Mozilla, Apple, and Microsoft root program policies, all CA Owners 
with one or more Root or Intermediate CAs trusted for the issuance of 
S/MIME certificates should have completed an S/MIME BR audit by now and 
disclosed the audit details on each applicable CCADB record.

I recently added tracking to https://crt.sh/mozilla-disclosures to flag 
missing and inconsistent disclosures of S/MIME BR audits.  Since this 
crt.sh report is currently flagging issues for a number of CA Owners, I 
thought I would share a summary of the findings here.  In my view, most (if 
not all) of these issues should be treated as incidents per 
https://www.ccadb.org/cas/incident-report.

*CA Owners with Missing S/MIME BR Audit details:*

GoDaddy:
Several applicable Root Certificate records don’t specify any S/MIME BR 
audit details.  The WebTrust seals on https://certs.godaddy.com/repository do 
not include an S/MIME BR seal.  Has GoDaddy undergone an S/MIME BR audit?

TWCA:
No S/MIME BR audit details have been disclosed on one Root Certificate 
record.  This root CA isn’t directly trusted for S/MIME, but it counts as 
S/MIME-capable because it’s cross-certified by a root that is trusted for 
S/MIME.  Is ticking “Audits Same as Parent” the required resolution here?

DigitalSign - Certificadora Digital, S.A.:
Two root certificates have only the Email trust bit set in NSS, but the 
corresponding Root Certificate records in CCADB have no S/MIME BR audit 
details disclosed.  Has DigitalSign undergone an S/MIME BR audit?

eMudhra:
Two applicable Intermediate Certificate records don’t specify any S/MIME BR 
audit details.  Is ticking “Audits Same as Parent” the required resolution 
here?

Entrust:
Two applicable Root Certificate records don’t specify any S/MIME BR audit 
details.  Although these roots have been distrusted for further issuance of 
TLS server certificates, they are still fully trusted for the issuance of 
S/MIME certificates.  Has Entrust undergone an S/MIME BR audit?

Siemens (externally-operated Sub-CAs under Entrust):
Several applicable Intermediate Certificate records specify no S/MIME BR 
audit details.  Has Siemens undergone an S/MIME BR audit?

Ministerie van Defensie (externally-operated Sub-CA under PKIoverheid):
One applicable Intermediate Certificate record doesn’t specify any S/MIME 
BR audit details.  See also 
https://bugzilla.mozilla.org/show_bug.cgi?id=1911335.

LAWtrust:
One applicable Root Certificate record doesn’t specify any S/MIME BR audit 
details.  Has LAWtrust undergone an S/MIME BR audit?

Cybertrust Japan (externally-operated Sub-CA under SECOM Trust Systems):
One applicable Intermediate Certificate record doesn’t specify any S/MIME 
BR audit details.  See also 
https://bugzilla.mozilla.org/show_bug.cgi?id=1950574.

*CA Owners with Inconsistent Disclosure of S/MIME BR Audit details:*

Asseco Data Systems:
One applicable Root Certificate record doesn’t specify any S/MIME BR audit 
details.  Although this root certificate is not present in root stores, its 
signature can be validated by a doppelganger root that is.  (The serial 
number of this self-signed root certificate appears in the CRL, but I think 
it’s questionable as to whether self-signed certificates can actually be 
revoked in this manner.  This self-signed root certificate is also listed 
in OneCRL, but AIUI OneCRL is only applicable to Firefox’s use of TLS 
server certificate chains, meaning that it’s out of scope for Mozilla’s 
interest in S/MIME).

DigiCert:
Two applicable Root Certificate records don’t specify any S/MIME BR audit 
details.  These root CAs aren’t directly trusted for S/MIME, but they do 
inherit S/MIME-capability via cross-certification from other DigiCert 
roots.  (The CCADB records for the cross-certificates all specify “Audits 
Same as Parent”, and the corresponding parent records do specify S/MIME BR 
audit details).

Microsec:
Similar to the Asseco Data Systems case, a doppelganger Root Certificate 
record doesn’t specify any S/MIME BR audit details.

Cybertrust Japan (externally-operated Sub-CA under SECOM Trust Systems):
One applicable Intermediate Certificate record doesn’t specify any S/MIME 
BR audit details (see above), whereas a doppelganger Intermediate 
Certificate record does.  See also 
https://bugzilla.mozilla.org/show_bug.cgi?id=1950574.

Telia:
In two cases, the S/MIME BR audit Statement Date differs between a Root 
Certificate record and a corresponding Intermediate Certificate 
(cross-certificate) record.

*apple-disclosures*

I have also added tracking to https://crt.sh/apple-disclosures to flag 
missing and inconsistent disclosures of S/MIME BR audits.  This report 
currently flags issues for some additional CA Owners, but since crt.sh is 
not yet tracking all of the intricacies of Apple’s root store metadata 
there may be some false positives. 

--
Rob Stradling
Distinguished Engineer
Sectigo Limited

-- 
You received this message because you are subscribed to the Google Groups 
"CCADB Public" group.
To unsubscribe from this group and stop receiving emails from it, send an email 
to [email protected].
To view this discussion visit 
https://groups.google.com/a/ccadb.org/d/msgid/public/6e3d6380-ec26-440e-bbce-cea11af47023n%40ccadb.org.

Reply via email to