MRSP 2.9: S/MIME BRs Transition Timeline
Ben Wilson
Greetings,
Our proposal for a migration plan towards having Certification Authorities (CAs) follow the CA/Browser Forum’s Baseline Requirements for S/MIME Certificates (S/MIME BRs) is as follows, keeping in mind that the Effective Date for version 1.0.0 of the S/MIME BRs is September 1, 2023, and assuming that ETSI and WebTrust audit criteria are in place for S/MIME BR audits by September 1, 2023.
Any root CA certificate being considered for inclusion after September 1, 2023, must be audited according to the S/MIME BRs if the email trust bit is to be enabled, and the CA operator’s CP or CPS must state that they follow the current version of the S/MIME BRs. Note that the CA operator’s first S/MIME BR audit may be a Point-in-Time audit if the audit period will be less than 60 days, and the audit statement may list non-compliances to be resolved within the next annual audit period.
CA root certificates and subordinate CA certificates that are technically capable of issuing S/MIME certificates that chain up (either directly or transitively) to a root certificate that has the email (S/MIME) trust bit enabled in Mozilla's CA Certificate Program shall be audited with a Period-of-Time audit according to the S/MIME BRs between September 1, 2023, and August 31, 2024, and annually thereafter. For CA operators to maintain their current annual audit cycles, the new S/MIME BR audit should be provided along with the other audits that the CA operator provides annually.
The audit period start date for the first S/MIME BR audit will be September 1, 2023, or earlier.
At the CA operator’s option, the first S/MIME BR audit may cover the entire audit period.
The initial audit period start date for the first S/MIME BR audit cannot be before the effective date of a CA operator’s CP or CPS that confirms the CA operator’s compliance with the current version of the S/MIME BRs.
If the CA operator’s existing regular audit period for other audit types ends after October 30, 2023, then we will expect to receive an S/MIME BR audit that covers September 1, 2023, through the end of that audit period (i.e. a Period-of-Time audit).
If the CA operator’s first S/MIME BR audit period would be less than 60 days (e.g. audit period being September 1, 2023, to October 30, 2023), then a Point-in-Time audit may be performed.
The first S/MIME BR audit for each CA root certificate and subordinate CA certificate may include a reasonable list of non-compliances that the CA operator (or subordinate CA operator) is not yet in compliance with.
Only one Incident Bug needs to be filed containing the list of the non-compliances in a CA operator’s first S/MIME BR audit.
Submission of the second S/MIME BR audit report is expected to confirm that the issues that were listed in the first S/MIME BR audit report have been resolved.
We look forward to your constructive feedback on the proposed transition timeline.
Regards,
Ben and Kathleen