Thank you Rob.

On Tue, Oct 9, 2018 at 3:43 AM Rob Stradling via dev-security-policy <
[email protected]> wrote:

> "ACTION 6" of Mozilla's September 2018 CA Communication [1] reminded CAs
> of the Mozilla Root Store Policy requirement [2] that
> non-technically-constrained intermediate CA certificates...
>    "MUST be publicly disclosed in the CCADB by the CA that has their
>     certificate included in Mozilla's root program. The CA with a
>     certificate included in Mozilla's root program MUST disclose this
>     information within a week of certificate creation, and before any
>     such subordinate CA is allowed to issue certificates."
>
> In their responses to "ACTION 6" [3], most CAs indicated that...
>    "We are aware of the requirements for intermediate certificate
>     disclosure and have processes in place to ensure that these
>     requirements are met"
>
>  In fact, every CA  except Trustis (no longer issuing certificates) and
Certicamara (still hasn't responded) indicated that they comply with this
policy.

There are currently 20 undisclosed non-technically-constrained
> intermediates, belonging to 6 Root Owners, on "Rob's naughty list" [4]
> (snapshot at [5]).  All 20 were undisclosed and listed (on [4]) on the
> day the responses to [1] were due (September 30th), which means that
> they have not been disclosed "within a week of certificate creation".
>
> So, ISTM that the "processes in place to ensure that these requirements
> are met" are insufficient/broken for at least the following Root Owners:
>    - Certicámara
>

These are the same four that I reported to Certicamara back in April via
https://bugzilla.mozilla.org/show_bug.cgi?id=1455128 I emailed them
yesterday about this and their failure to respond to the September CA
Communication.

   - DigiCert
>

Looks like DigiCert disclosed these within a few hours of your email.

   - DocuSign (OpenTrust/Keynectis)
>

 I filed https://bugzilla.mozilla.org/show_bug.cgi?id=1497700

   - SECOM Trust Systems CO., LTD.
>    - SwissSign AG
>

This is incredibly disappointing given
https://bugzilla.mozilla.org/show_bug.cgi?id=1455132 (among other recent
SwissSign issues)

   - Telia Company (formerly TeliaSonera)
>
> I reopened https://bugzilla.mozilla.org/show_bug.cgi?id=1451953 This is
also disappointing given Telia's other recent issues.

Wayne, Kathleen:
> Given the number of times that all the CAs in Mozilla's Root Program
> have been reminded about Mozilla's requirements for disclosing
> intermediate certs, I wouldn't blame you if you decided to add these 20
> intermediate certs [5] to OneCRL immediately!
>
>
I think we should give this serious consideration, although it doesn't help
with the majority of these that are trusted for email.

>
> [1]
>
> https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J00003rMGLL
>
> [2]
>
> https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#532-publicly-disclosed-and-audited
>
> [3]
>
> https://ccadb-public.secure.force.com/mozillacommunications/CACommResponsesOnlyReport?CommunicationId=a051J00003rMGLL&QuestionId=Q00078,Q00079
>
> [4] https://crt.sh/mozilla-disclosures#undisclosed
>
> [5] https://crt.sh/reports/20181009_MozillaDisclosures.html#undisclosed
>
> --
> Rob Stradling
> Senior Research & Development Scientist
> Email: [email protected]
>
>
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