Thank you for the incident report Pedro.

On Thu, Nov 1, 2018 at 1:36 AM Pedro Fuentes via dev-security-policy <
[email protected]> wrote:

>
> This intermediate was created under a new Root and its main purpose was to
> issue the required test certificates to request inclusion. As the Root was
> not yet included in CCADB when the Intermediate was created and therefore
> could not be disclosed normally, we didn't follow our standard procedure.
> Additionally, the Intermediate has not been yet put into production and
> not linked yet to our certificate management platform, so we didn't do the
> additional verifications before first issuances.
>
> Finally the new Root was included by Mozilla in mid August 2018, and at
> that point we should have detected the issue, but our process didn't
> consider this situation and we failed to notice the problem.
>
> Nevertheless, it must be also understood that for a new Intermediate under
> a Root not yet in CCADB it doesn't seem possible to fully follow section
> 5.3.2 (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) because at that
> point (and until some months later) the parent Root wouldn't be considered
> in CCADB and in my understanding it's technically not possible to add
> subordinate CAs.
>
> We totally assume our mistake, as we should have proactively verified
> compliance with the Mozilla Policy once the new Root was activated in CCADB
> and detect ourselves the lack of disclosure of this intermediate, even
> before the new Root was included in the Mozilla Program, but as explained
> our procedure didn't consider this situation.
>
> This is good feedback. We may add a step to the Mozilla root inclusion
process that explicitly calls out the need for all unconstrained
intermediates to be disclosed in CCADB when a root is added to CCADB.

- Wayne
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