Hi Rob,
 
thank you for your efforts to improve the security of the web PKI.
 
We have conducted a quick investigation into the reported S/MIME audit issue 
and believe we have found the possible root cause of the issue.
For the problematic "Microsec e-Szigno Root CA 2009" root, Microsec has a 
"working" root certificate that is included in several Root Programs.
For different reasons, two doppelganger certificates have been issued for this 
root, which are not active and are not directly trusted by any of the Root 
Programs.
These two doppelganger certificates have been added to CCADB as subordinate 
certificates under the "working" root CA certificate and the audits are marked 
"as parents".
Microsec has a total of 3 root certificates for this root entity, but there are 
4 instances in CCADB, as shown in the following table.
We do not know how and why, but one of the doppelganger certificates has been 
added to CCADB as a separate root as well, and this may be the source of the 
problem.
 
Microsec e-Szigno Root CA 2009

SHA256 hash
Cert Serial Number
CCADB Unique ID
Included in CCADB as
Included in Root Programs

3C5F81FEA5FAB82C64BFA2EAECAFCDE8E077FC8620A7CAE537163DF36EDBF378
00C27E43044E473F19
A000164
root
included

8E8C6EBF77DC73DB3E38E93F4803E62B6B5933BEB51EE4152F68D7AA14426B31
00C27E43044E473F18
A010460
root
not included

8E8C6EBF77DC73DB3E38E93F4803E62B6B5933BEB51EE4152F68D7AA14426B31
00C27E43044E473F18
A004417
subordinate
same as parent

72F9AF2158181BAF16D60C9B4E6F4BD7CA8D2341AD48AFDB67CB4C8332D546F6
00E8849639AB66105A
A006945
subordinate
same as parent
 
 
We contact the CCADB operators and ask them what to do to solve this issue.
 
Kind Regards,
 
Sándor
 
Dr. Sándor SZŐKE
dep. Director of eIDAS Trust Services
 

 
Microsec Ltd.  |  Ángel Sanz Briz Road 13.
Budapest, H-1033 Hungary
Graphisoft Park Southern Area, Building SP3, 3th floor
T: +36 1 802-4418  |   +36 1 505-4477 / 488
 <mailto:[email protected]> [email protected]
microsec.com
 
From: 'Rob Stradling' via CCADB Public <[email protected]> 
Sent: Wednesday, March 5, 2025 10:04 PM
To: CCADB Public <[email protected]>
Subject: Missing or Inconsistent Disclosure of S/MIME BR Audits
 
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
 
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