CFCA: OCSP Responder Certificate Profile Deviations and OCSP Service Issues
Categories
(CA Program :: CA Certificate Compliance, task)
Tracking
(Not tracked)
People
(Reporter: songxinlei, Assigned: songxinlei)
Details
(Whiteboard: [ca-compliance] [crl-failure] [ocsp-failure])
Attachments
(3 files)
User Agent: Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_7) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/146.0.0.0 Safari/537.36
Steps to reproduce:
Preliminary Incident Report
Summary
- Incident description: On April 7, 2026, CFCA received an email from security researcher reporting multiple non-conformance issues with CFCA's PKI infrastructure against the CA/Browser Forum Baseline Requirements. The reported issues include: (1) OCSP responder certificate profile deviations: Key Usage contains unauthorized "nonRepudiation" flag, missing required "id-pkix-ocsp-nocheck" extension, KeyUsage and basicConstraints not marked as critical, and inclusion of prohibited CRL Distribution Points extension; (2) OCSP service returning "unauthorized" for Subordinate CA certificate status queries despite the certificate containing an OCSP AIA extension; (3) CRL signature algorithm ASN.1 encoding error where the signatureAlgorithm field lacks the required NULL parameter.
- Relevant policies:
- BR 7.1.2.8 - OCSP Responder Certificate Profile;
- BR 7.1.2.8.7 - OCSP Responder Key Usage;
- BR 7.1.2.8.6 - id-pkix-ocsp-nocheck Extension;
- BR 7.1.2.8.4 - OCSP Responder Basic Constraints;
- BR 7.1.2.8.2 - cRLDistributionPoints;
- BR 4.9.9 - OCSP response for Subordinate CA Certificate;
- RFC 4055 Section 5 (which is referenced by RFC 5280 Section 4.1.2.3) - AlgorithmIdentifier
- Source of incident disclosure: Third-party Reported, since it's reported to individual CFCA employees rather than through the official public Certificate Problem Report (CPR) mechanism documented our CP/CPS, this issues not being detected and processed in a timely manner
Update Preliminary Incident Report:
Preliminary Incident Report
Summary
- Incident description: On April 7, 2026, CFCA received an email from security researcher reporting multiple non-conformance issues with CFCA's PKI infrastructure against the CA/Browser Forum Baseline Requirements. The reported issues include: (1) OCSP responder certificate profile deviations: Key Usage contains unauthorized "nonRepudiation" flag, missing required "id-pkix-ocsp-nocheck" extension, KeyUsage and basicConstraints not marked as critical, and inclusion of prohibited CRL Distribution Points extension; (2) OCSP service returning "unauthorized" for Subordinate CA certificate status queries despite the certificate containing an OCSP AIA extension; (3) CRL signature algorithm ASN.1 encoding error where the signatureAlgorithm field lacks the required NULL parameter.
- Relevant policies:
- BR 7.1.2.8 - OCSP Responder Certificate Profile;
- BR 7.1.2.8.7 - OCSP Responder Key Usage;
- BR 7.1.2.8.6 - id-pkix-ocsp-nocheck Extension;
- BR 7.1.2.8.4 - OCSP Responder Basic Constraints;
- BR 7.1.2.8.2 - cRLDistributionPoints;
- BR 4.9.9 - OCSP response for Subordinate CA Certificate;
- RFC 4055 Section 5 (which is referenced by RFC 5280 Section 4.1.2.3) - AlgorithmIdentifier
- Source of incident disclosure: Third-party Reported (identity to be disclosed pending reporter consent). The disclosure was reported to individual CFCA employees rather than through the official public Certificate Problem Report (CPR) mechanism documented in our CP/CPS, resulting in these issues not being detected and processed in a timely manner
Updated•6 months ago
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Comment 2•6 months ago
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If CA compliance incidents or issues have distinct and unrelated root causes, then they should be tracked in separate bugs.
Hi, we've received reporter consent, so updating the preliminary incident report as follows:
Preliminary Incident Report
Summary
- Incident description: On April 7, 2026, CFCA received an email from security researcher reporting multiple non-conformance issues with CFCA's PKI infrastructure against the CA/Browser Forum Baseline Requirements. The reported issues include: (1) OCSP responder certificate profile deviations: Key Usage contains unauthorized "nonRepudiation" flag, missing required "id-pkix-ocsp-nocheck" extension, KeyUsage and basicConstraints not marked as critical, and inclusion of prohibited CRL Distribution Points extension; (2) OCSP service returning "unauthorized" for Subordinate CA certificate status queries despite the certificate containing an OCSP AIA extension; (3) CRL signature algorithm ASN.1 encoding error where the signatureAlgorithm field lacks the required NULL parameter.
- Relevant policies:
- BR 7.1.2.8 - OCSP Responder Certificate Profile;
- BR 7.1.2.8.7 - OCSP Responder Key Usage;
- BR 7.1.2.8.6 - id-pkix-ocsp-nocheck Extension;
- BR 7.1.2.8.4 - OCSP Responder Basic Constraints;
- BR 7.1.2.8.2 - cRLDistributionPoints;
- BR 4.9.9 - OCSP response for Subordinate CA Certificate;
- RFC 4055 Section 5 (which is referenced by RFC 5280 Section 4.1.2.3) - AlgorithmIdentifier
- Source of incident disclosure: Third-party Reported by xipki. The disclosure was reported to individual CFCA employees rather than through the official public Certificate Problem Report (CPR) mechanism documented in our CP/CPS, resulting in these issues not being detected and processed in a timely manner
(In reply to incident-reporting from comment #2)
If CA compliance incidents or issues have distinct and unrelated root causes, then they should be tracked in separate bugs.
Thank you for the guidance on separating bugs with distinct root causes.
After our preliminary analysis, we have identified two categories of issues affecting different infrastructure components:
Category 1: OCSP-Related Issues
- OCSP Responder certificate profile deviations
- OCSP service functionality issues
- Affected: 4 OCSP Responder certificates
Category 2: CRL-Related Issues
- CRL encoding issues (signatureAlgorithm ASN.1 encoding)
- Affected: 4 CRLs (EV RCA Root CA + EV/OV/DV OCA Subordinate CAs)
Actions Taken:
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Created separate bug for CRL issues
- Bug #2033412: CFCA: CRL signatureAlgorithm Missing NULL Parameter (RFC 4055 Section 5)
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Rename this bug to focus on OCSP issues
- Current title: "CFCA: OCSP Responder Certificate Profile Deviations and CRL Encoding Issues"
- Updated title: "CFCA: OCSP Responder Certificate Profile Deviations and OCSP Service Issues"
Thank you for your guidance.
Full Incident Report
Summary
- CA Owner CCADB unique ID: A000272
- Incident description: CFCA OCSP Responder certificates for EV RCA, EV OCA, OV OCA, and DVOCA contained multiple BR 7.1.2.8 profile deviations including unauthorized Key Usage flags, missing required extensions, prohibited extensions, and non-critical extension marking. Additionally, DVOCA(Subordinate CA) certificate OCSP status query returns "unauthorized".
- Timeline summary:
- Non-compliance start date: 2022-10-17(DVOCA Certificate issued)
- Non-compliance identified date: 2026-04-07
- Non-compliance end date: 2026-05-26
- Relevant policies:
- BR 7.1.2.8 (OCSP Responder Certificate Profile)
- BR 7.1.2.8.2 (Prohibited: CRL Distribution Points extension)
- BR 7.1.2.8.4 (Critical extension marking requirements)
- BR 7.1.2.8.6 (Required: id-pkix-ocsp-nocheck extension)
- BR 7.1.2.8.7 (Prohibited Key Usage: nonRepudiation)
- BR 4.9.9 (OCSP responder must provide certificate status)
- Source of incident disclosure: Third Party Reported by XiPKI
Impact
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Total number of certificates: 3 OCSP Responder certificates (EV RCA, EV OCA, OV OCA) + 1 Subordinate CA certificate (DVOCA - OCSP status query issue only)
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Total number of "remaining valid" certificates: 3 OCSP Responder certificates remain valid pending remediation
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Affected certificate types:
- OCSP Responder Certificates (infrastructure certificates)
- Subordinate CA Certificate (DVOCA) - OCSP status query issue only
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Incident heuristic: Affected OCSP Responder certificates files will be uploaded as attachments to this Bug for verification.
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Was issuance stopped in response to this incident, and why or why not?: No. OCSP Responder certificates are infrastructure certificates. Subscriber certificate issuance continues unaffected.
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Analysis: N/A
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Additional considerations: N/A
Timeline
All times in this timeline are in Beijing Time (CST, UTC+8) unless explicitly marked.
| Date Time | Event |
|---|---|
| 2012-08-08 11:07 | EV RCA (Root CA) certificate issued |
| 2012-08-08 13:50 | EV RCA & EV OCA OCSP certificate templates created |
| 2014-10-29 | EV RCA OCSP certificate template last adjustment |
| 2015-08-03 09:44 | OV OCA & DVOCA OCSP certificate templates created (DVOCA certificate not issued) |
| 2023-09-15 | BR 2.0.0 took effect |
| 2026-04-02 23:28 CET (UTC+1) | Reporter (XiPKI) sends first email to cps@cfca.com.cn - Reports OCSP "unauthorized" issue |
| 2026-04-03 23:43 CET (UTC+1) | Reporter sends follow-up email - Adds OCSP certificate profile issues and CRL encoding issues |
| 2026-04-07 18:02 | Reporter forwards emails to CFCA employees (non-official channel) |
| 2026-04-09 03:31 | CPR platform submission - WebHook notification failed (content exceeded 4096 char limit) |
| 2026-04-13 ~09:00 | CFCA discovers forwarded email and processes incident |
| 2026-04-20 18:35 | CRL issues separated to Bug 2033412 per Mozilla recommendation |
Related Incidents
After searching Mozilla Bugzilla, we found related OCSP compliance incidents from other CA Owners:
| Bug | Date | Description |
|---|---|---|
| 1996857 | 2025-10-28 | IZENPE: OCSP Responder certificates included nonRepudiation Key Usage (BR 7.1.2.8.7 violation). |
| 1879552 | 2024-02-08 | Microsoft PKI Services: OCSP Responder returned "unknown" status due to database synchronization failure. |
| 1653680 | 2020-07-14 | IdenTrust: OCSP Responder certificate missing id-pkix-ocsp-nocheck extension (BR 7.1.2.8.6 violation). |
| 1649951 | 2020-07-02 | DigiCert: OCSP Delegated Responder certificates missing id-pkix-ocsp-nocheck extension. |
| 1649964 | 2020-07-02 | PKIoverheid: Incorrect OCSP Delegated Responder Certificate. |
| 1649963 | 2020-07-02 | Atos: Incorrect OCSP Delegated Responder Certificate. |
| 1649962 | 2020-07-02 | SECOM: Incorrect OCSP Delegated Responder Certificate. |
| 1649961 | 2020-07-02 | Actalis: Incorrect OCSP Delegated Responder Certificate. |
| 1649947 | 2020-07-02 | Microsec: Incorrect OCSP Delegated Responder Certificate. |
| 1649945 | 2020-07-02 | HARICA: Incorrect OCSP Delegated Responder Certificate. |
| 1649944 | 2020-07-02 | Camerfirma: Incorrect OCSP Delegated Responder Certificate. |
Root Cause Analysis
Contributing Factor #1: OCSP Responder Certificate Profile Deviations (BR 7.1.2.8)
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Description: OCSP certificate templates created in 2012-2015 have been used for issuance without review against subsequent BR updates. New requirements introduced over time were not incorporated into templates. While OCSP services remained operational, these deviations exposed systemic deficiencies in CA infrastructure certificate management. Remediation completed: after each BR update, all certificate templates are reviewed for compliance; quarterly self-audit includes template review; process formalized as standard procedure.
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Timeline:
- 2012-08-08 11:07: EV RCA (Root CA) certificate issued
- 2012-08-08 13:50: EV RCA & EV OCA OCSP certificate templates created
- 2014-10-29: EV RCA OCSP template last adjustment
- 2015-08-03 09:44: OV OCA & DVOCA OCSP certificate templates created
- 2026-04-07: External researcher discovers issues
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Detection: External security researcher (XiPKI) reported these problems. The issue persisted undetected for 10-12 years because infrastructure certificates were not reviewed against evolving BR requirements.
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Interaction with other factors: Certificate profile errors + Internal checks not covering OCSP/CRL contributed to this problem undetected.
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Root Cause Analysis methodology used: 5-Whys
Contributing Factor #2: Manual process missed for updating OCSP Service for certificated issed by offline Root CA
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Description: OCSP service returns "unauthorized" status when queried for DVOCA Subordinate CA certificate status. Database sync operation failure occurred when DVOCA Subordinate CA certificate was issued in August 2015, because we haven't issued any DV subscriber certificates, this problem remained undetected from 2015-2026 without causing actual impact.
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Timeline:
- 2022: CFCA DV OCA issued by our RCA, but missed the steps to update OCSP service.
- 2026-04-07: External researcher discovers issue
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Detection: External security researcher discovered via OCSP query testing. Because there haven't conducted periodic OCSP functional testing, and quarterly self-audit did not include Subordinate CA certificate status queries, and DVOCA had not issued subscriber certificates so the issue had no visible operational impact. After interviewing with our OCSP and CA operator and develop teams, we identified that there's an manual process to update OCSP lookup database for certificates issued by offline Root CA.
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Interaction with other factors: Related to Factor #3: if quarterly self-audit included OCSP functional testing, this issue would have been detected earlier).
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Root Cause Analysis methodology used: Direct investigation (database sync testing) + Technical constraint assessment
Contributing Factor #3: Internal Compliance Checks Not Covering Infrastructure Certificates
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Description: Internal compliance checking was focused on subscriber certificates, missed the infrastructure certificates because the requirements for infrastructure certificates are stable and low-risk. However, BR requirements evolved over time, and infrastructure certificates were not reviewed against new requirements. Additionally, no OCSP functional testing was conducted, leads to this issue undetected. Our quarterly self-audit now includes OCSP functional testing for Subordinate CA certificate status queries.
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Timeline:
- 2012-2015: OCSP certificate profiles created and updated
- 2026-04-07: External researcher discovers issues that internal systems missed
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Detection: External researcher report revealed that infrastructure certificates were not reviewed against evolving BR requirements. After inspection from the database, and interviewing with our operation team, we found that the certificate profile was created long time ago, and have been using these profiles to issue OCSP certificates.
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Interaction with other factors: This factor enabled Factor #1 and Factor #2 to remain undetected. If infrastructure certificates had been reviewed against BR changes, Factor #1 template deviations would have been identified. If OCSP functional testing had been conducted, Factor #2 database sync issue would have been detected.
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Root Cause Analysis methodology used: Process gap analysis and interviewing with related team members
Contributing Factor #4: CPR platform WebHook notification content exceeded size limit and errored-out
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Description: Reporter submitted issue report via CPR platform on 2026-04-09, but WebHook notification failed (enterprise WeChat notification not received), causing CFCA to not detect the report promptly. After reviewing service logs, we found that our CPR platform WebHook notification content exceeded 4096 character limit, causing notification delivery failure.
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Timeline:
- 2026-04-09 03:31:54: Reporter submitted via CPR platform
- 2026-04-09: WebHook notification failed (enterprise WeChat not received)
- 2026-04-13 ~09:00: CFCA discovered report via forwarded email
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Detection: CFCA internal investigation (log analysis, configuration check) discovered the WebHook failure. The failure was not detected promptly because it's been treated as success if one of the WebHook or Email calls works.
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Root Cause Analysis methodology used: Direct investigation (log analysis, configuration check)
Lessons Learned
What went well
- N/A
What didn't go well
- BR change monitoring: Updates not reviewed against infrastructure certificates
- RCA offline zone Sub CA issuance: Manual operation did not execute OCSP database sync (operational manual lacked explicit procedure)
- CPR platform WebHook notification failed
Where we got lucky
- Reporter used responsible disclosure and tried many ways to get in touch with us.
- No subscriber certificates affected
- OCSP services remain functional despite certificate profile deviations
Additional
- N/A
Action Items
| Action Item | Kind | Corresponding Root Cause(s) | Evaluation Criteria | Due Date | Status |
|---|---|---|---|---|---|
| Re-issue OCSP Responder certificates with correct BR 7.1.2.8 profile (EV RCA + EV/OV OCA) | Prevent | #1 | New certificates pass compliance check | 2026-05-26 | Ongoing |
| Improve "New CA Creation Guide" with OCSP database sync checklist | Prevent | #2 | Guide includes data sync checklist (OA process ensures execution) | 2026-04-28 | Complete |
| Add manual certificate checking for CA infrastructure certificates in deployment process (OCSP) | Detect | #3 | OCSP certificates pass manual certificate check before issuance | 2026-05-14 | Complete |
| Establish systematic BR change review process covering all certificate types | Prevent | #1, #3 | BR changes reviewed within 7 days | 2026-04-24 | Complete |
| Add OCSP service functional testing (Subordinate CA certificate queries) | Detect | #2, #3 | Quarterly OCSP testing during self-audit | 2026-04-24 | Complete |
| Fix CPR platform WebHook notification mechanism (content truncation handling) | Prevent | #4 | WebHook notifications succeed (truncate if exceeds limit) | 2026-04-16 | Complete |
| Enhance CPR platform user confirmation functionality | Prevent | #4 | CPR submission returns ticket number and confirmation email | 2026-05-31 | Ongoing |
Appendix
Affected OCSP Responder Certificates
The following is the complete corpus of OCSP Responder certificates affected by this incident (3 certificates total).
The EV RCA, EV OCA and OV OCA OCSP Responder Certificate are uploaded above.
Hi, the action items are going as planned, no other updates yet.
| Assignee | ||
Comment 10•5 months ago
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Hi, we're monitoring this bug. No furthur updates yet.
| Assignee | ||
Comment 11•5 months ago
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Hi, the action items are progressing as planned, no furthur updates yet.
| Assignee | ||
Comment 12•5 months ago
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Hi, the action items are progressing as planned, no furthur updates yet.
| Assignee | ||
Comment 13•4 months ago
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Hi, the OCSP Responder certificates has been reissued, so we're updating the Action Items as follows:
| Action Item | Kind | Corresponding Root Cause(s) | Evaluation Criteria | Due Date | Status |
|---|---|---|---|---|---|
| Re-issue OCSP Responder certificates with correct BR 7.1.2.8 profile (EV RCA + EV/OV OCA) | Prevent | #1 | New certificates pass compliance check | 2026-05-26 | Complete |
| Improve "New CA Creation Guide" with OCSP database sync checklist | Prevent | #2 | Guide includes data sync checklist (OA process ensures execution) | 2026-04-28 | Complete |
| Add manual certificate checking for CA infrastructure certificates in deployment process (OCSP) | Detect | #3 | OCSP certificates pass manual certificate check before issuance | 2026-05-14 | Complete |
| Establish systematic BR change review process covering all certificate types | Prevent | #1, #3 | BR changes reviewed within 7 days | 2026-04-24 | Complete |
| Add OCSP service functional testing (Subordinate CA certificate queries) | Detect | #2, #3 | Quarterly OCSP testing during self-audit | 2026-04-24 | Complete |
| Fix CPR platform WebHook notification mechanism (content truncation handling) | Prevent | #4 | WebHook notifications succeed (truncate if exceeds limit) | 2026-04-16 | Complete |
| Enhance CPR platform user confirmation functionality | Prevent | #4 | CPR submission returns ticket number and confirmation email | 2026-05-31 | Ongoing |
| Assignee | ||
Comment 14•4 months ago
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Hi, the Action Item about CPR is completed, all action items are done, here's the updated Action Items table:
| Action Item | Kind | Corresponding Root Cause(s) | Evaluation Criteria | Due Date | Status |
|---|---|---|---|---|---|
| Re-issue OCSP Responder certificates with correct BR 7.1.2.8 profile (EV RCA + EV/OV OCA) | Prevent | #1 | New certificates pass compliance check | 2026-05-26 | Complete |
| Improve "New CA Creation Guide" with OCSP database sync checklist | Prevent | #2 | Guide includes data sync checklist (OA process ensures execution) | 2026-04-28 | Complete |
| Add manual certificate checking for CA infrastructure certificates in deployment process (OCSP) | Detect | #3 | OCSP certificates pass manual certificate check before issuance | 2026-05-14 | Complete |
| Establish systematic BR change review process covering all certificate types | Prevent | #1, #3 | BR changes reviewed within 7 days | 2026-04-24 | Complete |
| Add OCSP service functional testing (Subordinate CA certificate queries) | Detect | #2, #3 | Quarterly OCSP testing during self-audit | 2026-04-24 | Complete |
| Fix CPR platform WebHook notification mechanism (content truncation handling) | Prevent | #4 | WebHook notifications succeed (truncate if exceeds limit) | 2026-04-16 | Complete |
| Enhance CPR platform user confirmation functionality | Prevent | #4 | CPR submission returns ticket number and confirmation email | 2026-05-31 | Complete |
| Assignee | ||
Comment 15•4 months ago
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The closure report will be updated soon, no other updates.
| Assignee | ||
Comment 16•4 months ago
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As all Action Items has been completed, we're updating the Report Closure.
Report Closure Summary
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Incident description: CFCA OCSP Responder certificates (EV RCA, EV OCA, OV OCA) contained multiple BR 7.1.2.8 profile deviations: unauthorized Key Usage flag (nonRepudiation), missing id-pkix-ocsp-nocheck extension, prohibited CRL Distribution Points extension, and non-critical extension marking. DVOCA Subordinate CA certificate OCSP queries returned "unauthorized" due to an offline Root CA database sync failure. A CPR platform WebHook notification also failed due to content exceeding the 4096-character limit.
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Incident Root Cause(s):
- OCSP certificate templates created in 2012-2015 have been used for issuance without review against subsequent BR updates.
- Manual process missed for updating OCSP Service for certificated issued by offline Root CA, database sync operation failure occurred when DVOCA Subordinate CA certificate was issued in August 2015.
- Internal compliance checking was focused on subscriber certificates, missed the infrastructure certificates because the requirements for infrastructure certificates are stable and low-risk.
- CPR platform WebHook silently failed when submission content exceeded the 4096-character limit.
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Remediation description: All 3 OCSP Responder certificates were revoked and re-issued with correct BR 7.1.2.8 profiles. The "New CA Creation Guide" was updated with an OCSP database sync checklist. Mandatory pre-issuance checking for CA infrastructure certificates and quarterly OCSP functional testing were added. A systematic BR change review process covering all certificate types was established. The CPR platform WebHook was fixed to truncate oversized content and deliver full content via email, and a user-facing confirmation (ticket number) was added.
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Commitment summary: CFCA commits to ongoing quarterly OCSP functional testing, 7-day BR change review for all certificate types, mandatory pre-issuance verifying for all CA infrastructure certificates.
All Action Items disclosed in this report have been completed as described, and we request its closure.
Comment 17•4 months ago
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This is a final call for comments or questions on this Incident Report.
Otherwise, it will be closed on approximately 2026-06-16.
Updated•4 months ago
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Description
•