On Mon, Jan 7, 2019 at 6:05 AM Rob Stradling <[email protected]> wrote:

> On 02/01/2019 22:40, Wayne Thayer via dev-security-policy wrote:
> <snip>
> > Yes, the idea is that CT could remove the need to enforce intermediate
> > disclosures via policy.
>
> Hi Wayne.  That seems at odds with (my understanding of) the purpose of
> the disclosure requirement.
>
> The relevant phrase in the Mozilla Root Store Policy is "publicly
> disclosed and audited".  The CCADB captures audit information, whereas
> CT logs do not.
>
> How would Mozilla check that a CT-logged intermediate is covered by an
> appropriate audit, if the CA is no longer required to disclose that
> information to the CCADB?
>
> That is a valid point, and combined with Ryan and Kurt's comments about
option #4, seems to eliminate CT as a replacement for the intermediate
disclosure requirement.

I believe that our aim should be to force disclosure before an intermediate
can be used successfully in Firefox, not to render an intermediate that is
discovered prior to disclosure unusable.Option #2 (immediately and
permanently add undisclosed intermediates to OneCRL) also relies on
discovery of the undisclosed intermediate and some mechanism for
automatically loading it into OneCRL, and that makes it fragile -
especially when Jacob's proposed modifications are added in to the mix.

I think Ryan's second choice of option 1 (treat non-disclosure as an
incident) plus option 3 (enforce disclosure in Firefox via intermediate
preloading) is the best approach to enforcing Mozilla's intermediate
disclosure policy. Unless there are additional comments, I will plan to
recommend that Mozilla implement option 3 once intermediate preloading has
been deployed.

Thanks everyone for your input on this topic.

- Wayne
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