Hello! 

We want to start a conversation about bringing more clarity and consistency 
to expectations for CP/CPS content. We posted this here so that non-CA/B F 
members can provide feedback and because we can think of several ways to do 
it. An update to the Baseline Requirements, CCADB policy update, or an 
update to one of the Root programs’ policies.  

This isn’t the first incident about CP/CPS content the community has had 
but it’s a good place to start with for background 
https://bugzilla.mozilla.org/show_bug.cgi?id=2009525.  

We have two proposals to start the discussion. If people have other 
proposals or feedback about these, please share them. 

Proposal 1 – Update Section 2.2 of the Baseline Requirements 

Change the existing language:  

The CA SHALL publicly give effect to these Requirements and represent that 
it will adhere to the latest published version. The CA MAY fulfill this 
requirement by incorporating these Requirements directly into its 
Certificate Policy and/or Certification Practice Statements or by 
incorporating them by reference using a clause such as the following (which 
MUST include a link to the official version of these Requirements): [Name 
of CA] conforms to the current version of the Baseline Requirements for the 
Issuance and Management of Publicly-Trusted TLS Server Certificates 
published at https://www.cabforum.org. In the event of any inconsistency 
between this document and those Requirements, those Requirements take 
precedence over this document.  

 

To something like: 

 

The CA MUST publicly give effect to these Requirements and represent that 
it will adhere to the latest published version. The CA MAY fulfill this 
requirement by incorporating these Requirements by reference into its 
Certificate 
Policy and/or Certification Practice Statements. If the CA does this the 
reference must be in Section 1.1 and MUST list which documents it is 
referencing by title and must include the link to the document’s landing page 
i.e. “Baseline Requirements for the Issuance and Management of Publicly‐Tru
sted TLS Server Certificates https://cabforum.org/working-groups/serve
r/baseline-requirements/”. The CA MAY also include the following in Section 
1.1: “In the event of any inconsistency between this document and those 
Requirements, those Requirements take precedence over this document.” CAs 
that incorporate requirements by reference SHOULD NOT include details about 
required practices. CAs that incorporate requirements by reference MUST 
include details in places where the referenced documents express optional 
requirements i.e. “No stipulation, SHOULD, SHOULD NOT, MAY, optional. 

 

In practice this would result in, for example, Section 4.2.1 (for TLS 
certs) CAs would have to describe if they reuse validation data but not 
required items such as: “Applicant information MUST include, but not be 
limited to, at least one Fully-Qualified Domain Name”. 

 

Proposal 2 – Adopt a style similar to Matter PKI by the Connectivity 
Standards Alliance (CSA) 

When CA's submit a CPS to the CSA it is laid out where the requirement is 
stated. Following that there is a spot for the CA response when required. 
Example: 

4.2 - Certificate Application Processing 
It is the responsibility of the CA/RA to verify that the information in a 
Certificate Application is accurate. 
CA Response: <insert response> 

CA Response: 

Before issuing Matter Certificates, the CA verifies Vendor identity & 
information through the following process: 1) Vendor requests a Distributed 
Compliance Ledger (DCL) challenge to prove ownership of their DCL private 
key; 2) The CA verifies the DCL challenge; 3) The CA retrieves Requester 
data for the RAD and Certificate Application; 4) The CA verifies the 
Vendor's information against a known database; 5) The CA generates the RAD 
and Certificate Application with the verified data; 6) Vendor signs the RAD 
and Certificate Application; and 7) The CA creates the Vendor for PAI 
issuance. 

Given that we have been moving the CA/B F requirements in a direction where 
we have greater specificity and less leeway we think this is a good time to 
revisit more specific requirements for CP/CPS content as well. 

Thanks! 

Trevoli Ponds-White 

Amazon Trust Services 

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