It's unambiguous, at least, since you can publish CRLs for Root CAs (and
that's covered as part of the auditing criteria, FWIW), and also solves any
issues with cross-certificates, by making it clear it's any CRL for
anything with CA:TRUE, "regardless" of how its used.
To Rob's question, the intent in drafting this requirement, which was an
existing (and long-standing) requirement from Microsoft that is also
consistent with past requests (not requirements) from Mozilla, Google, and
Apple, is that revocation information is updated by this deadline. This was
discussed during the balloting phase, precisely to allow CAs to schedule
ceremonies to generate new CRLs to ensure that, as of the deadline, all
revocation services provided were and are compliant.
This was explicitly called out in
https://github.com/cabforum/documents/pull/195 , which stated:
"These requirements come into effect 2020-09-30, as issuing new CRLs
requires a new ceremony."
As of today (intentionally chosen to be a Wednesday, so that there were no
beginning/end of week surprises), the published CRLs and OCSP responses
available via the CA's repository were and are expected to comply with the
profile set forth in the Baseline Requirements. A reasonCode was and is
expected to be published today, and so the question is "Does the published
CRL contain a reasonCode"?