Hi all,

We were curious for community feedback on the applicability of TLS BR
revocation
timelines
<https://cabforum.org/working-groups/server/baseline-requirements/requirements/#4911-reasons-for-revoking-a-subscriber-certificate>
when a publicly-trusted CA Owner has violated CAA expectations.

Studying CAA-related incident reports disclosed to Bugzilla over the past
~5 years, it appears there *might* be mixed interpretations of the required
revocation timelines when CAA is violated. The evaluations below were based
on a quick, non-comprehensive scan of CAA-related incident reports
disclosed to Bugzilla, where we attempted to interpret the understood
revocation timelines described in the incident reports based on observed
revocation behavior, which wasn’t always clear.


   -

   SSL.com: CAA Empty set handling results in Wildcard issuance
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1932973> (certificates
   revoked within 24 hours)
   -

   SSL.com: Failure to process CAA records from one SubCA
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1938236> (certificates
   revoked within 24 hours)
   -

   DigiCert: Unclear Disclosure of CAA Issuer Domain Names
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1914911> (certificates
   revoked within 5 days)
   -

   GoDaddy: CAA checks passed when records contained incorrect variants of
   godaddy.com or starfieldtech.com
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1904749>] (certificates
   revoked within 5 days)
   -

   GoDaddy: CAA checks did not properly handle issuewild tag allowing FQDN
   SANs to be added to wildcard certs
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1904748> (certificates
   revoked within 5 days)
   -

   Google Trust Services: SXG certificates issued without correctly
   checking CAA restrictions
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1902670> (certificates
   revoked within 24 hours)
   -

   Apple: TLS certificates issued outside the TTL of the CAA record
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1841534> (certificates
   revoked within 5 days)
   -

   GlobalSign: Certificate issued to FQDN with malformed CAA
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1759854> (certificates
   revoked within 24 hours)
   -

   Amazon Trust Services: Missing CAA Check For Test Website Certificates
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1746945> (certificates
   revoked within 24 hours)
   -

   Let's Encrypt: CAA Rechecking bug
   <https://bugzilla.mozilla.org/show_bug.cgi?id=1619047> (certificates
   revoked within 5 days)


>From our view, it seems a 24-hour revocation window is more appropriate
than a 5-day window. If CAA is to be interpreted as a security function
explicitly enabled by a domain owner that is intended to prevent
certificate issuance by unauthorized CAs, it feels odd to treat this
differently than TLS BR 4.9.1.1 (2), which states “The Subscriber notifies
the CA that the original certificate request was not authorized and does
not retroactively grant authorization (CRLReason #9, privilegeWithdrawn);”.
We recognize that a request not being authorized and issuance not being
authorized are indeed distinct, but from our view they appear to
communicate the same conclusion in that from the subscriber’s perspective
issuance should not have taken place.

We were hoping to collect opinions from this group to ultimately inform
next steps, which might include clarifying expectations within the
CA/Browser Forum TLS BRs.

As always, additional discussion is welcome and we’re open to changing our
perspective.

Thanks for your consideration in participating in this discussion!

- Ryan, on behalf of the Chrome Root Program

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