Hi Rob, 

Thank you for the explanation; I understand now how my previous wording and 
response at F2F 65 could have been more precise.

The expectation that the “Validation Methods” field in the CCADB is 
populated is based upon technical enforcement within the system.


   1. 
   
   Introduced 
   
<https://docs.google.com/document/d/1yMLYQFNH2JnOixVsByC99uoQd8fFfZcKlKBu-vgy3CU/edit?tab=t.0#bookmark=id.u98ojkipqj1f>
 
   in September 2022 during a major CCADB release, the Validation Methods 
   field became a mandatory entry. Subsequently, whenever a root certificate 
   was added to an "Add/Update Root Request" Case (minimally, for annual 
   document disclosure requirements), the CCADB system enforced that this 
   field be populated before a CA Owner could successfully select 'Submit to 
   Root Store'. Attempting to submit without providing a value for this field 
   results in an error.
   2. 
   
   Similarly, CA Owners attempting to include a root certificate in a "Root 
   Inclusion Request" Case have to populate the Validation Methods field (and 
   several other root record fields in the CCADB) before being able to 
   successfully select 'Submit to Root Store'. Without this information, 
   submission will again result in an error. 
   

The expectation that the field be populated with accurate information comes 
from Section 1 <https://www.ccadb.org/policy#1-general-provisions> of the 
CCADB Policy that states: 

“Regardless of more specific provisions in these requirements, CA Owners 
have an overarching responsibility to keep the information in the CCADB 
about themselves, their operations and their certificates accurate, and to 
make updates in a timely fashion. Minimally, CA Owners with certificates 
included in a Root Store MUST ensure their information stored in the CCADB 
is kept up to date as changes occur.” 

Members at F2F 65 wanted a clear deadline for updating their information in 
this field. We chose July 15, 2025, to align with the deprecation of 
methods 3.2.2.4.2 and 3.2.2.4.15 from the CA/Browser Forum TLS Baseline 
Requirements.

Hopefully, this context helps better explain the expectation for the 
Validation Methods field in the CCADB. 

Thank you

-Chris


On Thursday, June 26, 2025 at 9:24:37 AM UTC-4 [email protected] wrote:

> This date is in line with the expectation that CA Owners will have 
updated their in-use TLS server authentication certificate validation 
methods for publicly-trusted hierarchies, following the recent 
<https://groups.google.com/a/ccadb.org/g/public/c/QOFzi8wGf8Y/m/Tg3ULE0KAgAJ> 
CCADB 
enhancement.

Hi Chris.  You may recall that I expressed surprise about this 
"expectation" at the recent CABForum F2F.  Allow me to explain.

The announcement for the recent 
<https://groups.google.com/a/ccadb.org/g/public/c/QOFzi8wGf8Y/m/Tg3ULE0KAgAJ> 
CCADB enhancement said (emphasis mine):

   - "The CCADB was updated to add the following TLS Certificate Domain and 
   IP Address Control Validation Methods as *options* for selection by CA 
   Owners"
   - "CA Owners implementing any of these methods *can* disclose their use"

I haven't been able to find any previous CCADB announcement regarding the 
Validation Methods field, and I also can't find any language in the newly 
updated CCADB Policy or in any of the Root Store policies that requires 
this field to be populated.  In contrast, there are clear MUST requirements 
for populating certain other fields (e.g., 
https://www.ccadb.org/policy#62-certificate-revocation-list-disclosures).

The reason for my surprise is that an "expectation" sounds like "SHOULD" or 
"MUST", whereas "options" and "can" sound like "MAY".  I have no problem 
with aiming to comply with clearly labelled SHOULD and MUST requirements 
that have achievable effective dates and that are enshrined in official 
policies, but ISTM that your "expectation" here is an implied and backdated 
"SHOULD" or "MUST" that is neither clearly labelled nor enshrined in policy.

Is there some other basis for your "expectation" that I've missed?

On Tuesday, June 17, 2025 at 1:45:30 PM UTC+1 Chris Clements wrote:

All,

The updated CCADB Policy <https://www.ccadb.org/policy> and Incident 
Reporting Guidelines <https://www.ccadb.org/cas/incident-report> have been 
published with an effective date of *July 15, 2025*. This date is in line 
with the expectation that CA Owners will have updated their in-use TLS 
server authentication certificate validation methods for publicly-trusted 
hierarchies, following the recent 
<https://groups.google.com/a/ccadb.org/g/public/c/QOFzi8wGf8Y/m/Tg3ULE0KAgAJ> 
CCADB enhancement.

CA Owners are strongly encouraged to align their CCADB disclosures with the 
expectations that become effective on July 15, 2025, as soon as reasonably 
possible. 

Please note, to comply with the updated CRL disclosure requirements 
described in Section 6.2 
<https://www.ccadb.org/policy#62-certificate-revocation-list-disclosures>, 
it is expected some CAs will need to update existing certificate records 
(e.g., modifying CRL disclosures to exactly match those included in 
certificates).

Thank you

-Chris, on behalf of the CCADB Steering Committee

On Fri, May 30, 2025 at 4:26 PM Chris Clements <[email protected]> wrote:

All, 

Thank you to everyone who provided valuable feedback on the proposed 
<https://github.com/mozilla/www.ccadb.org/pull/198> updates to the CCADB 
Policy and the Incident Reporting Guidelines (IRGs). Both artifacts have 
been enhanced thanks to the insightful recommendations and suggestions.

We want to reiterate the original objectives for this update:

   - Clarifying Root Store Operator expectations for CCADB disclosures.
   - Streamlining requirements across different root programs to reduce 
   redundancy.
   - Enhancing the simplicity and readability of the policy.

We plan to publish the updated CCADB Policy and IRGs later in June, with an 
effective date of July 1, 2025.

We appreciate your continued collaboration in making the CCADB a more 
effective and transparent resource for the community.

-Chris, on behalf of the CCADB Steering Committee

On Fri, May 2, 2025 at 10:48 AM Chris Clements <[email protected]> wrote:

All,

Following the community’s recent iteration 
<https://groups.google.com/a/ccadb.org/g/public/c/GIBHz9FUjHY/m/XOOLNpOFCAAJ> 
and improvement on the updated CCADB Incident Reporting Guidelines 
<https://www.ccadb.org/cas/incident-report> (IRGs), the CCADB Steering 
Committee has collaborated on an updated draft of the CCADB Policy.

The set of proposed updates are available here 
<https://github.com/mozilla/www.ccadb.org/pull/198>.

Objectives for this update include:

   - Clarifying Root Store Operator expectations related to CCADB 
   disclosures. Some of these clarifications were motivated by public Incident 
   Reports filed to Bugzilla over the past year.
   - Creating opportunities to (a) remove redundant/similar requirements 
   located across root program policies related to CCADB disclosures and (b) 
   encourage future simplicity.
   - Promoting simplicity and improving readability through a 
   reorganization of normative and non-normative requirements.

Additionally, minor updates are proposed to the IRGs (e.g., further 
streamlining the incident reporting closure process).

These proposals should not be considered “final”, but instead a “work 
in-progress” that we hope to enhance through community contributions. We 
welcome your feedback on these proposed updates and recommendations by *May 
23, 2025*. Please share your thoughts by replying to this email or, 
*preferably*, by suggesting edits directly on GitHub.

Thank you
-Chris, on behalf of the CCADB Steering Committee

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