Mozilla Root Store Policy

Version 2.5

1. Introduction

When distributing binary and source code versions of Firefox, Thunderbird, and other Mozilla-related software products, Mozilla includes with such software a set of X.509v3 root certificates for various Certification Authorities (CAs). The included certificates have their "trust bits" set for various purposes, so that the software in question can use the CA certificates to anchor a chain of trust for certificates used by SSL servers and S/MIME email users without having to ask users for further permission or information.

This policy covers how the default set of certificates and associated trust bits is maintained for software products distributed by Mozilla. Other entities distributing software based on ours are free to adopt their own policies. In particular, under the terms of the relevant Mozilla license(s) distributors of such software are permitted to add or delete CA certificates and modify the values of the trust bits in the versions that they distribute. However, as with other software modifications, by making such changes a distributor MAY well affect its ability to use Mozilla trademarks in connection with its versions of the software. See the Mozilla trademark policy for more information.

1.1 Scope

This policy applies, as appropriate, to certificates matching any of the following (and the CAs which control or issue them):

  1. CA certificates included in, or under consideration for inclusion in, the Mozilla root program.

  2. Intermediate certificates which have at least one valid, unrevoked chain up to such a CA certificate and which are not technically constrained to prevent issuance of working server or email certificates. Such technical constraints could consist of either:

    • an Extended Key Usage (EKU) extension which does not contain any of these KeyPurposeIds: anyExtendedKeyUsage, id-kp-serverAuth, id-kp-emailProtection; or:
    • name constraints which do not allow Subject Alternative Names (SANs) of any of the following types: dNSName, iPAddress, SRVName, rfc822Name
  3. End-entity certificates which have at least one valid, unrevoked chain up to such a CA certificate through intermediate certificates which are all in scope, such end-entity certificates having either:

    • an Extended Key Usage (EKU) extension which contains one or more of these KeyPurposeIds: anyExtendedKeyUsage, id-kp-serverAuth, id-kp-emailProtection; or:
    • no EKU extension.

The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in RFC 2119.

1.2 Policy Ownership

Mozilla has appointed a CA Certificate module owner and peers to evaluate new CA requests on our behalf and make decisions regarding all matters relating to CA certificates included in our root program.

Further, Mozilla has appointed a Mozilla CA Certificate Policy module owner and peers to maintain this policy. The policy will only be changed after public consultation with the Mozilla community, in order to ensure that all views are taken into account. You can contact the Mozilla CA Certificate Policy module team at certificates@mozilla.org if you have questions about this policy.

CAs or others objecting to a particular decision by either team MAY appeal to the Mozilla governance module owner who will make a final decision.

2. Certificate Authorities

2.1 CA Operations

CAs whose certificates are included in Mozilla's root program MUST:

  1. provide some service relevant to typical users of our software products;
  2. follow industry best practice for securing their networks, for example by conforming to the CAB Forum Network Security Guidelines or a successor document;
  3. enforce multi-factor authentication for all accounts capable of causing certificate issuance or performing Registration Authority or Delegated Third Party functions, or implement technical controls operated by the CA to restrict certificate issuance through the account to a limited set of pre-approved domains or email addresses;
  4. prior to issuing certificates, verify certificate requests in a manner that we deem acceptable for the stated purpose(s) of the certificates;
  5. verify that all of the information that is included in SSL certificates remains current and correct at time intervals of thirty-nine months or less; and
  6. otherwise operate in accordance with published criteria that we deem acceptable.

CAs MUST follow and be aware of discussions in the mozilla.dev.security.policy forum, where Mozilla's root program is coordinated. They are encouraged, but not required, to contribute to those discussions.

2.2 Validation Practices

We consider verification of certificate signing requests to be acceptable if it meets or exceeds the following requirements:

  1. All information that is supplied by the certificate subscriber MUST be verified by using an independent source of information or an alternative communication channel before it is included in the certificate.
  2. For a certificate capable of being used for digitally signing or encrypting email messages, the CA takes reasonable measures to verify that the entity submitting the request controls the email account associated with the email address referenced in the certificate or has been authorized by the email account holder to act on the account holder’s behalf.
  3. For a certificate capable of being used for SSL-enabled servers, the CA must ensure that the applicant has registered the domain(s) referenced in the certificate or has been authorized by the domain registrant to act on their behalf. This must be done using one or more of the 10 methods documented in section 3.2.2.4 of version 1.4.1 (and not any other version) of the CA/Browser Forum Baseline Requirements. The CA's CP/CPS must clearly specify the procedure(s) that the CA employs, and each documented procedure should state which subsection of 3.2.2.4 it is complying with. Even if the current version of the BRs contains a method 3.2.2.4.11, CAs are not permitted to use this method.
  4. For certificates marked as Extended Validation, the CA MUST comply with the latest version of the Guidelines for the Issuance and Management of Extended Validation Certificates.

2.3 Baseline Requirements Conformance

CA operations relating to issuance of certificates capable of being used for SSL-enabled servers MUST also conform to the latest version of the CA/Browser Forum Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates ("Baseline Requirements"). In the event of inconsistency between Mozilla’s Root Store Policy requirements and the Baseline Requirements, Mozilla’s Root Store Policy takes precedence. The following is a list of known places where this policy takes precedence over the Baseline Requirements. If you find an inconsistency that is not listed here, notify Mozilla so the item can be considered for addition or clarification.

  • Insofar as the Baseline Requirements attempt to define their own scope, the scope of this policy (section 1.1) overrides that. Mozilla thus requires CA operations relating to issuance of all SSL certificates in the scope of this policy to conform to the Baseline Requirements.

  • Mozilla reserves the right to accept audits by auditors who do not meet the qualifications given in section 8.2 of the Baseline Requirements, or refuse audits from auditors who do.

3. Documentation

3.1 Audits

Before being included and periodically thereafter, CAs MUST obtain certain audits for their root certificates and all of their intermediate certificates that are not technically constrained to prevent issuance of working server or email certificates. This section describes the requirements for those audits.

3.1.1 Audit Criteria

We consider the criteria for CA operations published in the following documents to be acceptable:

3.1.2 Required Audits

3.1.2.1 WebTrust

If being audited to the WebTrust criteria, the following audit requirements apply (see section 3.1.1 for specific version numbers):

3.1.2.2 ETSI

If being audited to the ETSI criteria, the following audit requirements apply (see section 3.1.1 for version numbers):

  • For the SSL trust bit, a CA and all subordinate CAs technically capable of issuing server certificates must have one of the following audits, with at least one of the noted policies or sets of policies:

    An audit showing conformance with the EVCP policy is required if issuing EV certificates.

  • For the email trust bit, a CA and all subordinate CAs technically capable of issuing email certificates must have one of the following audits, with at least one of the noted policies:

ETSI TS 102 042 and TS 101 456 audits are only acceptable for audit periods ending in July 2017 or earlier.

3.1.3 Audit Parameters

Full-surveillance period-of-time audits MUST be conducted and updated audit information provided no less frequently than annually. Successive audits MUST be contiguous (no gaps).

Point-in-time audit statements may be used to confirm that all of the problems that an auditor previously identified in a qualified audit statement have been corrected. However, a point-in-time assessment does not replace the period-of-time assessment.

Audit reports which are being supplied to maintain a certificate within the Mozilla root program MUST be provided to Mozilla via the CCADB within three months of the point-in-time date or the end date of the period.

3.1.4 Public Audit Information

The publicly-available documentation relating to each audit MUST contain at least the following clearly-labelled information:

  1. name of the company being audited;
  2. name and address of the organization performing the audit;
  3. Distinguished Name and SHA256 fingerprint of each root and intermediate certificate that was in scope;
  4. audit criteria (with version number) that were used to audit each of the certificates;
  5. a list of the CA policy documents (with version numbers) referenced during the audit;
  6. whether the audit is for a period of time or a point in time;
  7. the start date and end date of the period, for those that cover a period of time;
  8. the point-in-time date, for those that are for a point in time;
  9. the date the report was issued (which will necessarily be after the end date or point-in-time date); and
  10. For ETSI, a statement to indicate if the audit was a full audit, and which parts of the criteria were applied, e.g. DVCP, OVCP, NCP, NCP+, LCP, EVCP, EVCP+, QCP-w, Part1 (General Requirements), and/or Part 2 (Requirements for trust service providers).

3.2 Auditors

In normal circumstances, Mozilla requires that audits MUST be performed by a Qualified Auditor, as defined in the Baseline Requirements section 8.2.

If a CA wishes to use auditors who do not fit that definition, they MUST receive written permission from Mozilla to do so in advance of the start of the audit engagement. Mozilla will make its own determination as to the suitability of the suggested party or parties, at its sole discretion.

3.3 CPs and CPSes

We rely on publicly disclosed documentation (e.g., in a Certificate Policy and Certification Practice Statement) to ascertain that our requirements are met. Therefore, the following MUST be true:

  1. the publicly disclosed documentation provides sufficient information for Mozilla to determine whether and how the CA complies with this policy, including a description of the steps taken by the CA to verify certificate requests;

  2. the documentation is available from the CA’s official website;

  3. CPs and CPSes are made available to Mozilla under one of the following Creative Commons licenses (or later versions):

    • Attribution (CC-BY) 4.0
    • Attribution-ShareAlike (CC-BY-SA) 4.0
    • Attribution-NoDerivs (CC-BY-ND) 4.0
    • Public Domain Dedication (CC-0) 1.0

    or a set of equally permissive licensing terms accepted by Mozilla in writing. If no such license is indicated, the fact of application is considered as permission from the CA to allow Mozilla and the public to deal with these documents, and any later versions for root certificates which are included in Mozilla's trust store, under CC-BY-ND 4.0.

CPs and CPSes MUST be reviewed and updated as necessary at least once every year, as required by the Baseline Requirements. CAs MUST indicate that this has happened by incrementing the version number and adding a dated changelog entry, even if no other changes are made to the document.

4. Common CA Database

Mozilla manages its root program using the Common CA Database (CCADB). CAs with certificates in Mozilla’s root program MUST use the CCADB, and are bound by the latest published version of the Common CCADB Policy, which is incorporated here by reference.

When required by the CCADB Policy, Mozilla’s root program may be contacted by email.

Mozilla has requirements for the use of the CCADB above and beyond those in the CCADB Policy, as follows:

4.1 Additional Requirements

  • If the revocation of an intermediate certificate chaining up to a root in Mozilla’s root program is due to a security concern, as well as performing the actions defined in the CCADB Policy, a security bug must be filed in Bugzilla.

4.2 Surveys

Mozilla may conduct a survey of CAs from time to time using the CCADB. CAs are required to respond to the surveys with accurate information, within the timescale defined in the survey.

5. Certificates

5.1 Algorithms

Root certificates in our root program, and any certificate which chains up to them, MUST use only algorithms and key sizes from the following set:

  • RSA keys whose modulus size in bits is divisible by 8, and is at least 2048.
  • Digest algorithms: SHA-1 (see below), SHA-256, SHA-384, or SHA-512.
  • ECDSA keys using one of the following curve-hash pairs:
    • P‐256 with SHA-256
    • P‐384 with SHA-384

5.1.1 SHA-1

CAs MAY sign SHA-1 hashes over end-entity certificates which chain up to roots in Mozilla's program only if all the following are true:

  1. The end-entity certificate:

    • is not within the scope of the Baseline Requirements;
    • contains an EKU extension which does not contain either of the id-kp-serverAuth or anyExtendedKeyUsage key purposes;
    • has at least 64 bits of entropy from a CSPRNG in the serial number.
  2. The issuing certificate:

    • contains an EKU extension which does not contain either of the id-kp-serverAuth or anyExtendedKeyUsage key purposes;
    • has a pathlen:0 constraint.

Point 2 does not apply if the certificate is an OCSP signing certificate manually issued directly from a root.

CAs MAY sign SHA-1 hashes over intermediate certificates which chain up to roots in Mozilla's program only if the certificate to be signed is a duplicate of an existing SHA-1 intermediate certificate with the only changes being all of:

  • a new key (of the same size);
  • a new serial number (of the same length);
  • the addition of an EKU and/or a pathlen constraint to meet the requirements outlined above.

CAs MAY sign SHA-1 hashes over OCSP responses only if the signing certificate contains an EKU extension which contains only the id-kp-ocspSigning EKU.

CAs MAY sign SHA-1 hashes over CRLs for roots and intermediates only if they have issued SHA-1 certificates.

CAs MUST NOT sign SHA-1 hashes over other data, including CT pre-certificates.

5.2 Forbidden and Required Practices

CA operations MUST at all times be in accordance with the applicable CP and CPS.

CAs MUST maintain a certificate hierarchy such that the included certificate does not directly issue end-entity certificates to customers (i.e. the included certificate signs intermediate issuing certificates), as described in section 6.1.7 of the Baseline Requirements.

CAs MUST maintain current best practices to prevent algorithm attacks against certificates. As such, all new certificates MUST have a serial number greater than zero, containing at least 64 bits of output from a CSPRNG.

CAs MUST NOT issue certificates that have:

  • ASN.1 DER encoding errors;
  • invalid public keys (e.g., RSA certificates with public exponent equal to 1);
  • duplicate issuer names and serial numbers (except that a Certificate Transparency pre-certificate is allowed to match the corresponding certificate);
  • incorrect extensions (e.g., SSL certificates that exclude SSL usage, or authority key IDs that include both the key ID and the issuer’s issuer name and serial number); or
  • cRLDistributionPoints or OCSP authorityInfoAccess extensions for which no operational CRL or OCSP service exists.

5.3 Intermediate Certificates

All certificates that are capable of being used to issue new certificates, and which directly or transitively chain to a certificate included in Mozilla’s CA Certificate Program, MUST be operated in accordance with this policy and MUST either be technically constrained or be publicly disclosed and audited.

A certificate is deemed as capable of being used to issue new certificates if it contains an X.509v3 basicConstraints extension with the cA boolean set to true. The term "subordinate CA" in this section refers to any organization or legal entity that is in possession or control of a certificate that is capable of being used to issue new certificates.

These requirements include all cross-certified certificates which chain to a certificate that is included in Mozilla’s CA Certificate Program.

5.3.1 Technically Constrained

We encourage CAs to technically constrain all subordinate CA certificates. For a certificate to be considered technically constrained, the certificate MUST include an Extended Key Usage (EKU) extension specifying all extended key usages that the subordinate CA is authorized to issue certificates for. The anyExtendedKeyUsage KeyPurposeId MUST NOT appear within this extension.

If the certificate includes the id-kp-serverAuth extended key usage, then the certificate MUST be Name Constrained as described in section 7.1.5 of version 1.3 or later of the Baseline Requirements.

If the certificate includes the id-kp-emailProtection extended key usage, it MUST include the Name Constraints X.509v3 extension with constraints on rfc822Name, with at least one name in permittedSubtrees, each such name having its ownership validated according to section 3.2.2.4 of the Baseline Requirements.

Instead of complying with the above paragraph, intermediate certificates issued before 22nd June 2017 may, until 15th January 2018, comply with the following paragraph:

If the certificate includes the id-kp-emailProtection extended key usage, then all end-entity certificates MUST only include e-mail addresses or mailboxes that the issuing CA has confirmed (via technical and/or business controls) that the subordinate CA is authorized to use.

5.3.2 Publicly Disclosed and Audited

We recognize that technically constraining subordinate CA certificates as described above may not be practical in some cases. All certificates that are capable of being used to issue new certificates, that are not technically constrained, and that directly or transitively chain to a certificate included in Mozilla’s root program MUST be audited in accordance with Mozilla’s Root Store Policy and MUST be publicly disclosed in the CCADB by the CA that has their certificate included in Mozilla’s root program. The CA with a certificate included in Mozilla’s root program MUST disclose this information within a week of certificate creation, and before any such subordinate CA is allowed to issue certificates. All disclosure MUST be made freely available and without additional requirements, including, but not limited to, registration, legal agreements, or restrictions on redistribution of the certificates in whole or in part.

6. Revocation

CAs MUST revoke Certificates that they have issued upon the occurrence of any event listed in the appropriate subsection of section 4.9.1 of the Baseline Requirements, according to the timeline defined therein.

CAs MUST maintain an online 24x7 repository mechanism whereby application software can automatically check online the current status of all unexpired certificates issued by the CA.

For end-entity certificates, CRLs MUST be updated and reissued at least every seven days, and the value of the nextUpdate field MUST NOT be more than ten days beyond the value of the thisUpdate field.

For end-entity certificates, if the CA provides revocation information via an Online Certificate Status Protocol (OCSP) service:

  • it MUST update that service at least every four days; and
  • responses MUST have a defined value in the nextUpdate field, and it MUST be no more than ten days after the thisUpdate field; and
  • the value in the nextUpdate field MUST be before or equal to the notAfter date of all certificates included within the BasicOCSPResponse.certs field or, if the certs field is omitted, before or equal to the notAfter date of the CA certificate which issued the certificate that the BasicOCSPResponse is for.

7. Root Store Changes

Changes that are motivated by a security concern such as certificate misissuance or a root or intermediate compromise MUST be treated as a security-sensitive, and a secure bug filed in Bugzilla.

7.1 Inclusions

We will determine which CA certificates are included in Mozilla's root program based on the benefits and risks of such inclusion to typical users of our products. We will consider adding additional CA certificates to the default certificate set upon request only by an authorized representative of the subject CA. We will make such decisions through a public process, based on objective and verifiable criteria.

We will not charge any fees to have a CA’s certificate(s) included in Mozilla's root program.

We reserve the right to not include certificates from a particular CA in our root program. This includes (but is not limited to) cases where we believe that a CA has caused undue risks to users’ security, e.g. by knowingly issuing certificates without the knowledge of the entities whose information is referenced in those certificates.

To request that its certificate(s) be added to Mozilla's root program a CA SHOULD submit a formal request by submitting a bug report into the mozilla.org Bugzilla system, filed against the "CA Certificates" component of the "mozilla.org" product. Mozilla’s wiki page, "Applying for root inclusion in Mozilla products", provides further details about how to submit a formal request. The request MUST be made by an authorized representative of the subject CA, and MUST include the following:

  1. the certificate data (or links to the data) for the CA certificate(s) requested for inclusion;
  2. for each CA certificate requested for inclusion, whether or not the CA issues certificates for each of the following purposes within the certificate hierarchy associated with the CA certificate:
    • SSL-enabled servers
    • digitally-signed and/or encrypted email;
  3. for each CA certificate requested for inclusion, whether the CA issues Extended Validation certificates within the certificate hierarchy associated with the CA certificate and, if so, the EV policy OID associated with the CA certificate;
  4. a Certificate Policy and Certification Practice Statement (or links to a CP and CPS) or equivalent disclosure document(s) for the CA or CAs in question; and
  5. information as to how the CA has fulfilled the requirements stated above regarding its verification of certificate signing requests and its conformance to a set of acceptable operational criteria.

We will reject requests where the CA does not provide such information within a reasonable period of time after submitting its request.

7.2 Updates

Changes MAY be made to root certificates that are included in Mozilla's root program as follows:

  1. enabling a trust bit in a root certificate that is currently included, may only be done after careful consideration of the CA’s current policies, practices, and audits, and may be requested by a representative of the CA or a representative of Mozilla by submitting a bug report into the mozilla.org Bugzilla system, as described in Mozilla’s wiki page, "Applying for root inclusion in Mozilla products";
  2. enabling EV in a root certificate that is currently included, may only be done after careful consideration of the CA’s current policies, practices, and audits, and may be requested by a representative of the CA or a representative of Mozilla by submitting a bug report into the mozilla.org Bugzilla system, as described in Mozilla’s wiki page, "Applying for root inclusion in Mozilla products";
  3. disabling a root is the act of turning off one or more of the trust bits (SSL or email), and may be requested by a representative of the CA or a representative of Mozilla by submitting a bug report into the mozilla.org Bugzilla system, as described in the Root Change Process;
  4. a representative of the CA or a representative of Mozilla may request that a root certificate be removed by submitting a bug report into the mozilla.org Bugzilla system, as described in the Root Change Process.

7.3 Removals

Mozilla MAY, at its sole discretion, decide to disable (partially or fully) or remove a certificate at any time and for any reason. This may happen immediately or on a planned future date. Mozilla will disable or remove a certificate if the CA demonstrates ongoing or egregious practices that do not maintain the expected level of service or that do not comply with the requirements of this policy.

Mozilla will take any steps we deem appropriate to protect our users if we learn that a CA has knowingly or intentionally mis-issued one or more certificates. This may include, but is not limited to disablement (partially or fully) or removal of all of the CA’s certificates from Mozilla’s root program.

The category of mis-issued certificates includes (but is not limited to) those issued to someone who should not have received them, those containing information which was not properly validated, those having incorrect technical constraints, and those using algorithms other than those permitted.

A failure to provide notifications or updates in the CCADB or as otherwise required in a timely manner SHALL also be grounds for disabling a CA’s root certificates or removing them from Mozilla's root program. For this policy and the CCADB policies, "a timely manner" means within 30 days of when the appropriate data or documentation becomes available to the CA, unless a Mozilla policy document specifies a different rule.

If Mozilla disables or removes a CA’s certificate(s) from Mozilla’s root program based on a CA’s actions (or failure to act) that are contrary to the Mozilla Root Store Policy, Mozilla will publicize that fact in newsgroups on the news.mozilla.org server, on Web pages in the mozilla.org and mozilla.com domains, in news releases sent to organizations specializing in computer and Internet news, and/or as an alert to the US-CERT organization of the U.S. Department of Homeland Security.

8. CA Operational Changes

CAs SHOULD NOT assume that trust is transferable. All CAs whose certificates are included in Mozilla's root program MUST notify Mozilla if:

  • ownership or control of the CA’s certificate(s) changes, or
  • ownership or control of the CA’s operations changes; or
  • there is a material change in the CA's operations.

CAs should err on the side of notification if there is any doubt. Mozilla will normally keep commercially sensitive information confidential. Throughout any change, CA operations MUST continue to meet the requirements of this policy. If one of the above events occurs, Mozilla MAY require additional audit(s) as a condition of remaining in the root program. CAs are encouraged to notify in advance in order to avoid unfortunate surprises.

In addition, one or more of the following sections MAY apply.

This section applies when one company buys or takes a controlling stake in a CA, or when an organization buys the private key of a certificate in Mozilla's root program.

Mozilla MUST be notified of any resulting changes in the CA's CP or CPS.

If the receiving or acquiring company is new to the Mozilla root program, there MUST be a public discussion regarding their admittance to the root program, which Mozilla must resolve with a positive conclusion before issuance is permitted.

8.2 Change in Operational Personnel

This section applies when operation of a certificate in Mozilla's root program is transferred to a different organization, whether by acquisition or contract.

The transferor MUST ensure that the transferee is able to fully comply with this policy. The transferor will continue to be responsible for the root certificate's private key until Mozilla has been provided with an audit statement (or opinion letter) confirming successful transfer of the root certificate and key. Issuance MUST NOT occur until the transferee has provided all the information required by the CCADB, and demonstrated to Mozilla that they have all the appropriate audits, CP/CPS documents and other systems in place.

The transferor MUST notify Mozilla about any necessary changes to EV status or trust bits in Mozilla's root store. If the transferee is receiving the (right to use the) associated EV policy OID(s), the transferor MUST confirm that the transferee has or will get the relevant audits before issuing EV certificates.

8.3 Change in Secure Location

The section applies when section 8.1 and/or section 8.2 applies, and when the cryptographic hardware related to a certificate in Mozilla's root store is consequently moved from one secure location to another.

This policy and the relevant WebTrust or ETSI requirements apply at all times, even during the physical relocation of a CA's online operations to a new data center and moving parts of an offline root certificate from one location to another. As such, a CA MUST always ensure that physical access to CA equipment is limited to authorized individuals, the equipment is operated under multiple person control, and unauthorized CA system usage is able to be detected at all times. The auditor MUST confirm that there are appropriate procedures in place to ensure that the requirements are met and that those procedures are followed.

The following steps MUST be taken by the organization(s) concerned:

  • Make sure the annual audit statements are current.
  • Notify Mozilla of the pending change.
  • Create a transfer plan (and legal agreement if more than one organization is involved) and have it reviewed by the auditors.
  • Stop new certificate issuance at the current site before the transfer begins.
  • Have an audit performed at the current site to confirm when the root certificate is ready for transfer, and to make sure the key material is properly secured.
  • The transfer ceremony should be witnessed by auditors and video recorded, with a physical exchange of the HSM or ciphertext containing the associated key material and certificates, and the multi-party authorization keys.
  • At the new site perform an audit to confirm that the transfer was successful, that the private key remained secure throughout the transfer, and that the root certificate is ready to resume issuance. This requirement may be met by including the transferred root certificate and key in the new owner's regular audits or by getting a PITRA.
  • Send links to the updated CP/CPS and the updated audit statements, opinion letter, or PITRA statement to Mozilla.

The regular annual audit statements MUST still happen in a timely manner.

The organization(s) concerned MUST immediately send a security report to Mozilla if a problem occurs.


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