Although it was not mentioned in the original bug, it may be worth adding that 
the certificates in [bug 
1867130](https://bugzilla.mozilla.org/show_bug.cgi?id=1867130) were also not 
revoked within 5 days of discovery. Entrust might've based the start of the 5 
day deadline at the time the "Director of compliance confirmed investigation 
conclusions to support team" at 2023-11-21 15:00 UTC with all certificates 
being revoked by 2023-11-26 14:50 UTC, but I don't think that's correct if that 
was the case.

On Friday, May 10th, 2024 at 5:27 PM, 'Ben Wilson' via 
dev-security-policy@mozilla.org <dev-security-policy@mozilla.org> wrote:

> Here are draft summaries of the additional historic incidents. I'll be adding 
> these to the Entrust Issues page: https://wiki.mozilla.org/CA/Entrust_Issues
>
> Invalid data in State/Province Field -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1658792
>
> It was initially discovered that Entrust had issued 395 OV SSL certificates 
> to a large international organization with “NA” for the state/province 
> information. Entrust worked on a drop-down list to prevent the error. 
> Certificate revocation would not occur within established timeframes, so Bug 
> #1658794 for delayed revocation was opened.
>
> Late Revocation for Invalid State/Province Issue -
> https://bugzilla.mozilla.org/show_bug.cgi?id=1658794
>
> This is the delayed revocation bug related to Bug #1658792, above. Entrust 
> said that when educating large institutions about rapid revocation, factors 
> include who owns a certificate, where it is deployed, and the type of system 
> or application that requires the certificate.It also said that it was 
> advocating automation with such institutions to help speed up certificate 
> replacement and to minimize human error.
>
> EV TLS Certificate incorrect jurisdiction -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1802916
>
> Entrust mis-issued 322 EV certificates with the wrong state and locality 
> jurisdiction fields due to complex data entry processes. Entrust implemented 
> a different automated dropdown system for jurisdiction selection. Certificate 
> revocation would not occur within established timeframes, so Bug #1804753 for 
> delayed revocation was opened.
>
> Delayed Revocation for EV TLS Certificate incorrect jurisdiction -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753
>
> This is the delayed revocation bug related to Bug #1802916, above. Entrust 
> listed 8 Subscribers who were pushing back on immediate certificate 
> revocation and the reasons given (e.g. extensions granted due to end-of-year 
> freezes). Entrust committed to “continue to develop and extend methods for 
> automatic certificate renewal.”
>
> Jurisdiction Locality Wrong in EV Certificate -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1867130
>
> Two EV TLS Certificates were mis-issued due to human error in the 
> Jurisdiction Locality field. (The incident revealed 340 additional accounts 
> needing similar updates.) Entrust said it would enhance its linting processes 
> to include possibly using an external service to validate locality data 
> against verified country data.
>
> SHA-256 hash algorithm used with ECC P-384 key -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1648472
>
> A Mozilla policy was adopted to require hashing with SHA-384 for an ECC P-384 
> key. Existing CAs using SHA-256 were not re-configured when Mozilla adopted 
> this policy. This incident revealed a serious gap in taking new requirements 
> and implementing them. Ryan Sleevi noted that linting was just a safety net 
> and not a systemic solution. Entrust was also criticized for the lack of 
> detail in its incident report and its decision to not revoke the certificates.
>
> Entrust committed to improving its monitoring and implementation of policy 
> changes to prevent similar incidents. Ryan set forth a number of proactive 
> systemic corrections that Entrust needed to take, rather than taking a 
> reactive stance on matters of non-compliance.
>
> Entrust committed to rigorous review of certificate profiles, browser policy 
> revisions, and industry developments. As a final comment, Ryan said, “My big 
> concern is, going forward, we see incident reports from Entrust take a more 
> systemic, holistic response, like Comment #16, to try and cover the 
> scenarios, and to provide sufficient detail about the situation and its 
> failures to understand how those relate. The goal isn't to make CAs wear 
> proverbial sackcloth, it's to try and make sure we're understanding how 
> things go wrong, so that we can effectively collaborate on identifying 
> solutions to avoid that going forward.”
>
> Late Revocation due to SHA-256 hash algorithm -
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1651481
>
> This bug is related to Bug #1648472.Entrust issued TLS certificates using ECC 
> P-384 keys hashed with SHA-256, contrary to Mozilla policy requiring SHA-384 
> for hashing. Entrust’s initial decision was to allow certificates to expire 
> naturally without revocation, but this was revised with a decision to revoke 
> all affected certificates. Entrust committed to: filing incident report 
> within one business day for future incidents, filing late revocation incident 
> reports within the required 24 hours or 5 days, as applicable, and advising 
> Subscribers about revocation within 24 hours or 5 days, or provide an 
> explanation if they are unable to meet such timeframes. Entrust was told it 
> needed to align its revocation procedures more closely with the Baseline 
> Requirements and Mozilla’s policy, especially in providing a detailed 
> rationale for any delays in revocation on a per-subscriber basis and ensuring 
> timely revocation in line with the Baseline Requirements.
>
> On Thu, May 9, 2024 at 8:13 PM Watson Ladd <watsonbl...@gmail.com> wrote:
>
>> Could we add a section for geographical incidents? This is slightly
>> outside your time window, but I think reading the series here has some
>> uncanny echos in the ones in your window.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1658792
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1658794
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1802916
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1867130
>>
>> On Tue, May 7, 2024 at 7:59 AM 'Ben Wilson' via
>> dev-security-policy@mozilla.org <dev-security-policy@mozilla.org>
>> wrote:
>>>
>>> Dear Mozilla Community,
>>>
>>> Over the past couple of months, a substantial number of compliance 
>>> incidents have arisen in relation to Entrust. We have summarized these 
>>> recent incidents in a dedicated wiki page: 
>>> https://wiki.mozilla.org/CA/Entrust_Issues. In brief, these incidents arose 
>>> out of certificate mis-issuance due to a misunderstanding of the EV 
>>> Guidelines, followed by numerous mistakes in incident handling (including a 
>>> deliberate decision to continue mis-issuance), which have been compounded 
>>> by a failure to remediate the issues in a timely fashion in line with 
>>> well-established norms and root store requirements.
>>>
>>> Our preliminary assessment of these incidents is that while they were 
>>> relatively minor initially, the poor incident response has substantially 
>>> aggravated them and the progress towards full remediation remains 
>>> unacceptably slow. This is particularly disappointing in light of previous 
>>> incidents in 2020 (#1651481 and #1648472), which arose out of similar 
>>> misunderstandings of the requirements, similar poor decision-making in the 
>>> initial response, and lengthy remediation periods that fell well below 
>>> expectations. Entrust gave commitments in those bugs to address the root 
>>> problems through process improvements, and it is concerning to see so 
>>> little improvement 4 years later.
>>>
>>> In light of these recent incidents, we are requesting that Entrust produce 
>>> a detailed report of them. This report should cover in detail:
>>>
>>> The factors and root causes that lead to the initial incidents, 
>>> highlighting commonalities among the incidents and any systemic failures;
>>>
>>> Entrust’s initial incident handling and decision-making in response to 
>>> these incidents, including any internal policies or protocols used by 
>>> Entrust to guide their response and an evaluation of whether their 
>>> decisions and overall response complied with Entrust’s policies, their 
>>> practice statement, and the requirements of the Mozilla Root Program;
>>>
>>> A detailed timeline of the remediation process and an apportionment of 
>>> delays to root causes; and
>>>
>>> An evaluation of how these recent issues compare to the historical issues 
>>> referenced above and Entrust’s compliance with its previously stated 
>>> commitments.
>>>
>>> Finally, Entrust’s report should include a detailed proposal on how it 
>>> plans to address the root causes of these issues. In light of previous 
>>> guarantees given by Entrust in 2020 to ensure speedy remediation in future 
>>> incidents, this proposal should include:
>>>
>>> Clear and concrete steps that Entrust proposes to take to address the root 
>>> causes of these incidents and delayed remediation;
>>>
>>> Measurable and objective criteria for Mozilla and the community to evaluate 
>>> Entrust’s progress in deploying these solutions; and
>>>
>>> A timeline for which Entrust will commit to meeting these criteria.
>>>
>>> We strongly recommend that Entrust go beyond their existing commitment to 
>>> offer systematic, automated solutions for effective remediation, like ACME 
>>> ARI and that it also include clear and measurable targets for the adoption 
>>> of these tools by new and existing subscribers.
>>>
>>> This report should be submitted to Mozilla dev-security-policy mailing list 
>>> for evaluation by the community and Mozilla, who will weigh whether 
>>> Entrust’s report presents a credible and effective path towards 
>>> re-establishing trust in Entrust’s operation. Submission should be no later 
>>> than June 7, 2024.
>>>
>>> We thank community members for their engagement on these issues and look 
>>> forward to their feedback on Entrust’s report and proposed commitments.
>>>
>>> Thanks,
>>>
>>> Ben Wilson
>>>
>>> Mozilla Root Program
>>>
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>>
>> --
>> Astra mortemque praestare gradatim
>
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