Hello,
Recently, we have been asked similar questions by multiple CAs regarding how accounturi should be handled when introducing ACME alongside existing issuance systems. This prompted us to re-examine the interpretation of RFC 8657 and BR 3.2.2.4.22 from a broader ecosystem perspective.
I would like to ask for feedback on our understanding regarding the use of Persistent DCV (RFC 8657 / BR 3.2.2.4.22), specifically about accounturi handling when a CA operates multiple issuance systems.
We are considering the following model and would appreciate feedback on whether this interpretation aligns with the intent of RFC 8657 Section 5.3.
Background
Our understanding is that RFC 8657 Section 5.3 requires issuance systems to “recognize the same parameters” when multiple issuance paths exist, while still allowing protocol-specific authorization decisions by the CA.
Case A: Manual issuance followed by ACME introduction
Phase 1
Phase 2
Case B: Non-ACME automated issuance and ACME
Phase 1
Phase 2
Key clarification
Although accounturi values may be issued by an ACME-related account management system, authorization for ACME issuance is explicitly controlled. In particular, manual-only accounturi values are intentionally rejected by ACME issuance, even though they are recognized.
Our understanding
Our understanding is that both cases satisfy RFC 8657 Section 5.3, because accounturi values are consistently recognized across issuance systems and authorization decisions are enforced per issuance protocol without ignoring or reinterpreting accounturi semantics.
We would appreciate any feedback on whether there are concerns or overlooked issues with this interpretation from a policy or root store perspective.
Thank you for your time and guidance.
Best regards,
ONO Fumiaki / 大野 文彰
(Japanese name order: family name first, in uppercase)
SECOM Trust Systems CO., LTD.
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