It is not entirely clear that a CA can use its CPS to enforce new requirements 
on third parties that are reporting key compromises in BR-compliant ways.  I 
get why it might be attractive to do so, but people should focus their efforts 
on fixing the BR language instead of just unilaterally claiming the right to 
fix it in their own CPS.

If a CA receives a BR-compliant problem report, I would expect it to be handled 
in a BR-compliant manner, including inspection of any evidence to see if it 
meets 4.9.1.1 (3), and taking appropriate action if it does.  If you don’t 
wanna, a better set of BRs is only a ballot away.

-Tim

From: Servercert-wg <[email protected]> On Behalf Of Aaron 
Gable via Servercert-wg
Sent: Wednesday, July 19, 2023 11:54 AM
To: Clint Wilson <[email protected]>; CA/B Forum Server Certificate WG Public 
Discussion List <[email protected]>
Subject: Re: [Servercert-wg] [secdir] Secdir last call review of 
draft-gutmann-testkeys-04

On Tue, Jul 18, 2023 at 4:59 PM Clint Wilson via Servercert-wg 
<[email protected]<mailto:[email protected]>> wrote:

  *   After exploring these possibilities (and quite probably missing others), 
I’m personally left with the same conclusion as I shared previously (and it 
sounds like there hasn’t been immediate disagreement with this as a positive 
action/next step either?), which is: further specification is a reasonable way 
to address at least some of the ambiguity around the method and/or means of 
communication necessary to constitute a CA being made aware of compromised keys.

     *   It further seems to me that this additional specification is 
probably(?) best suited for the BRs, but I also haven’t come up with a reason a 
CA couldn’t do something similar themselves in their own document(s). Perhaps 
some already do this?

The Let's Encrypt CP/CPS contains the following text:

-----
Section 4.9.12: Special requirements re key compromise
Key compromise must be demonstrated via the Certificate Revocation method of 
the ACME Protocol defined in RFC 8555, Section 7.6 by signing the request using 
the private key corresponding to the public key in the certificate
-----

We do on occasion block keys for other reasons (and in fact have already 
blocked the keys in draft-gutmann-testkeys-04), but this section attempts to 
state that the ACME API is the only method we accept for being made aware of 
key compromise. Perhaps this phrasing could be even clearer.

Aaron
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