Here's a question for Mozilla et. al.:
It's cute you have a magic DIY CRL. You accepted these assholes into your root program.
They lost the KEYS.
What is the screening process for CA's that can't be bothered to use a HSM?
Even Honest Achmed wasn't this careless.
IIRC up until very recently the screening process was "they report that they're good boys."
They didn't lose the keys, a sub-CA did.
Which is to say, sub-CAs in itself are a giant loophole that needs plugging. Especially since AFAIK nobody is bothering with name constraints (RFC5280 section 4.2.1.10).
>What is the screening process for CA's
it's done in the open, and you're even allowed to voice your cute opinion during the multi-week public commentary periods.
here is an overview https://wiki.mozilla.org/CA/Root_Inclusion_Overview