[Servercert-wg] Annual Update of CPS

[Ryan Dickson]

[Accidentally posted this in the MDSP
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/JoyItinU9iQ/m/0QECoxA2CAAJ?utm_medium=email&utm_source=footer>
thread related to the same topic, sorry if you're seeing this twice!]


Hi all,

I commented on the GitHub issue
<https://github.com/cabforum/servercert/issues/370#issuecomment-1315408729>,
but if we're looking at changing this requirement, I think we should do so
from the perspective of making it better aligned with root program
expectations.

Many root program policies include the expectation that a CA's policies
conform with the latest version of the BRs. Over the past five years, we've
seen, on average, eight ballots adopted to modify the BRs each year. While
it's true that not all ballots necessitate a CA's policies are updated, I
suspect if we studied it closer, we'd probably see CAs would need to update
their CP a few times a year, on average, to satisfy root program policies
that require policy “freshness.”

I'm not strongly proposing we change the yearly minimum requirement but
instead expressing concern about increasing it beyond every 365 days.

Somewhat related, I think some simple improvements could be made regarding
file naming conventions on policy documents to make it easier for CAs to
demonstrate compliance with policy “freshness” requirements.

For example, assume we required the current version of a CP always to be
located at [$ca_repository_base_url]/cp.pdf], or an otherwise static URL.
As new versions of the CP are published, they would replace the document
hosted at [$ca_repository_base_url]/cp.pdf] or the static URL. "Archived"
versions would then be appended with the version # of the then superseded
document (e.g., a superseded document would transition from
[$ca_repository_base_url]/cp.pdf] to
[$ca_repository_base_url]/cp-[$previousVersion].pdf]). Ultimately, this
makes it very easy for interested parties to find the most current version
of a given document.


The same format can apply to CPSs or TSPSs. To accommodate CAs that
maintain multiple CPs, we’ll need to think about ways of differentiating
URLs.

Root programs interested in doing so (or CCADB) could then monitor the
"current" policy document URLs and more easily verify the update
requirement has been met (i.e., regularly curl and hash
$ca_repository_base_url]/cp.pdf, and report when a policy is about to or
has recently become stale). Thinking beyond the immediate capabilities of
CCADB, perhaps someday it could automatically track version changes to
policy documents as they are identified by changes to the hashed value of
$ca_repository_base_url]/cp.pdf - reducing workload required by CAs to make
sure CCADB records are accurate and updated in a timely manner.

And, while we’re thinking outside the box - would requiring policy
documents be maintained in a common format that easily supports diffs and
tracked changes (i.e., Markdown, as we maintain the BRs) - improve our
collective policy management and conformance efforts?

Thanks,

Ryan


On Tue, Nov 15, 2022 at 11:01 AM Ben Wilson via Servercert-wg <
servercert-wg at cabforum.org> wrote:

> Hi Clint,
> On second thought, maybe my mind has changed about this. I invite others
> to chime in.
> Ben
>
> On Tue, Nov 15, 2022 at 7:16 AM Clint Wilson <clintw at apple.com> wrote:
>
>> Hi Ben,
>>
>> Can you share more of your reasoning for picking 398 days and in general
>> for decreasing the frequency of CP/CPS update requirements?
>>
>> Thanks!
>> -Clint
>>
>> On Nov 14, 2022, at 4:38 PM, Ben Wilson via Servercert-wg <
>> servercert-wg at cabforum.org> wrote:
>>
>> All,
>> Section 2.3 of the Baseline Requirements currently says, "The CA SHALL
>> develop, implement, enforce, and annually update a Certificate Policy
>> and/or Certification Practice Statement that describes in detail how the
>> CA implements the latest version of these Requirements."  I am considering
>> a proposal to revise that language to specify a 398-day period.  See https://github.com/cabforum/servercert/issues/370#issuecomment-1113441809
>>
>> Possible language would be:
>> "The CA SHALL develop, implement, enforce, and annually update a
>> Certificate Policy and/or Certification Practice Statement that describes
>> in detail how the CA implements the latest version of these Requirements.
>> The CA SHALL indicate conformance with this requirement by incrementing the
>> version number and adding a dated changelog entry *at least every 398
>> days*, even if no other changes are made to the document."
>> Thanks,
>> Ben
>>
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>>
>>
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