Hi everyone,

Following the set of updates made to the CCADB Policy
<https://www.ccadb.org/policy> last June
<https://groups.google.com/a/ccadb.org/g/public/c/J8aVHEWrMYs/m/bFM2shcrBgAJ>,
the CCADB Steering Committee has collaborated on a set of updates to
further clarify Root Store Operator expectations related to CCADB
disclosures.

Updates are also planned for the CCADB Incident Reporting Guidelines
<https://www.ccadb.org/cas/incident-report> (IRGs).

The set of proposed updates is available here
<https://github.com/mozilla/www.ccadb.org/pull/214> (“clean” policy
<https://github.com/mozilla/www.ccadb.org/blob/policy_2-1/policy.md> / IRG
<https://github.com/mozilla/www.ccadb.org/blob/policy_2-1/cas/incident-report.md>
).

Change summary:

Policy

   -

   Clarify expectations for subordinate CA ownership disclosure.
   -

   Effective September 15, 2026, require additional disclosures within PKI
   policy documents to more clearly establish the scope and applicability of
   policy documents.
   -

   Clarify audit expectations for CAs serving time-stamping use cases.
   -

   Clarify expectations related to explanatory letter disclosures for
   delayed audit statements.
   -

   Encourage Qualified Auditors to review public incident reports and offer
   an opinion on incident handling and remediation.
   -

   For audit periods beginning on or after January 15, 2027, audit
   statements must disclose sampling methodologies.
   -

   Clarify CRL disclosure expectations. Specifically, this policy update
   considers a new field (i.e., "All Full CRL URIs for This Hierarchy") being
   added to the CCADB that will expect a a properly formatted JSON array for
   the complete set of distinct HTTP URLs appearing in the
   `crlDistributionPoints` extension of the unexpired certificates issued by
   that CA. CA Owners can expect separate standard CCADB Enhancement Request
   communications regarding the deployment of this field, which will occur
   before the updated policy becomes effective.


IRGs

   -

   Clarify that audit findings must be the subject of an incident report.
   -

   Describe how Qualified Auditors can be involved in the incident
   reporting process.
   -

   Highlight that CA Owners should request a nextUpdate date “whiteboard”
   label to align with the soonest Action Item.
   -

   Highlight how CA Owners may add additional data fields to incident
   report appendices.



These proposals should not be considered “final”, but instead a “work
in-progress” that we hope to enhance through community contributions. We
welcome community feedback on these proposed updates and recommendations by
March 1, 2026. Please share your thoughts by replying to this email or,
preferably, by suggesting edits directly on GitHub.

Thank you,

Ryan (on behalf of the CCADB Steering Committee)

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