On Thu, Feb 6, 2020 at 5:44 PM Ryan Sleevi via dev-security-policy <
[email protected]> wrote:

<snip>

My recommendation is that, for audit periods ending within the next 30 or
> so days (meaning, effectively, for reports provided over the next 4 months,
> given the three month window before reporting), such situations are
> accepted despite the limited assurance they provide. Following that - that
> is, for any audit afterwards, there is zero exception, and revocation is
> required.
>
>
I'd like to see Mozilla require an incident report from CAs that can't or
won't follow the existing guidance (by either supplying a revised audit
statement, revoking the certificate, or adding it to OneCRL). A number of
CAs have resolved these issues by following this guidance and I recommend
against adding a grace period at this time for those who have not.

This places the onus on the CA to ensure their audit reports will meet
> Mozilla’s requirements.
>
>
In the future, I expect ALV to catch these issues as soon as the audit
report is published. Mistakes do happen, and I don't think our policy
should go straight to revocation upon an ALV failure due to an audit
statement error.

2) Should we accept a revised audit statement to include the SHA256
> > fingerprint of a certificate that was not previously listed and does not
> > have the same Subject + SPKI as other cert(s) listed in the audit
> > statement?
>
>
<snip>

I realize Mozilla uses OneCRL to address the gap there, but ostensibly this
> is a straight BR violation regarding providing continuous audits. The
> proposed revisions will make this unambiguously clearer, but either way,
> the best path to protect the most users is to require the CA to revoke such
> certificates.
>
> This also hopefully has the desired effect of forcing CAs to pay closer
> attention to the requirements placed on them, and ensure that the negotiate
> and scope their audits to ensure they’re actually meeting those
> requirements.
>
>
I agree, but I also think that ALV will cause these issues to be caught and
quickly corrected in the future (assuming the CA has properly disclosed all
CA certificates).
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