Mass Revocation Incident Preparation and Testing Plan
Ben Wilson
Certification Authority (CA) Operator
Mass Revocation Incident Preparation and Testing Plan (MRIP&TP)
Version History
CA Operator Contact Information
[Company Name]
[Address]
[Telephone]
[Email]
1. Introduction
The management of [CA Operator] recognizes that the continuity of essential CA services depends on effective certificate revocation and replacement processes. These processes are dependent on robust IT infrastructure, effective customer communication, and rapid response capabilities.
To mitigate risks associated with a Mass Revocation Event (MRE)—which could cause disruption to customers, financial losses, and damage to trust—management has authorized the development, implementation, and maintenance of this Mass Revocation Incident Preparation and Testing Plan (MRIP&TP).
The MRIP&TP is aligned with [CA Operator] policies, compliance obligations, and industry best practices. It provides a framework for MRE response, customer communication, certificate replacement, revocation, and plan testing in advance of an MRE. This plan also aims to ensure compliance with industry and root store requirements, such as the CA/Browser Forum TLS Baseline Requirements and Mozilla Root Store Policy.
2. Mission and Objectives
The mission of this plan is to ensure a well-coordinated, rapid, and effective response to a Mass Revocation Event while maintaining compliance and minimizing disruptions.
Plan objectives are to:
Define clear roles and responsibilities for the teams assigned with handling MREs;
Identify critical processes and time-sensitive milestones for mass revocation preparedness;
Provide timely, clear communication to customers and other stakeholders to minimize disruptions to the ecosystem and third parties;
Develop and document certificate revocation strategies and procedures to ensure swift certificate replacement and compliance with revocation deadlines;
Report any delayed revocations to Bugzilla; and
Improve readiness through effective training, testing, and continuous improvement of mass revocation procedures.
3. Scope
This plan applies to the scoping, implementation, execution, review, training, testing, and improvement of mass revocation processes at [CA Operator]. It supports compliance with Mozilla Root Store Policy Section 6.1.3 and covers:
Maintenance of a well-documented and actionable mass revocation plan;
Rapid communication with customer and affected third parties;
Certificate replacement strategies;
Revocation execution and publication of certificate status;
Operational coordination and team responsibilities;
Compliance with CA/Browser Forum requirements;
Demonstrating implementation and feasibility through annual testing consisting of simulations, tabletop exercises, or controlled test environments;
Incorporating lessons learned by making plan improvements; and
Third-party assessment and external compliance evaluation.
4. Definition and Declaration of an MRE
A Mass Revocation Event (MRE) is defined as:
The revocation of a substantial number of certificates within a relatively short timeframe due to a common cause, compliance requirement, or security incident. The impact threshold is based on the CA’s total issuance volume and operational scale.
A Mass Revocation Event would be triggered, and this plan will be activated, based on:
Absolute Volume Impact – Affects ≥ 100 certificates;
Relative Issuance Impact – Affects ≥1% of the CA’s active TLS certificates;
Timeframe Impact – Requires revocation within timeframes set forth in section 4.9.1.1 of the TLS Baseline Requirements; or
Operational Burden – Requires major customer outreach, urgent operational changes, or compliance reporting;
Or in response to any of the following:
Compromise or suspected compromise of a CA private key;
Compliance failures affecting a significant number of certificates; or
Discovery of a major vulnerability impacting server private keys (e.g., HeartBleed).
The Management Team will assess and declare a Mass Revocation Event based on these criteria.
5. Decision Points and Strategies
5.1 Initial Assessment and Activation
Upon identification of a potential MRE, the Management Team will:
Assess the incident’s scope and severity against the defined MRE criteria;
Issue an internal alert to notify team members of possible activation;
Determine affected certificate population and impacted customers;
Estimate timelines required to perform notification, replacement, and revocation;
Initiate a conference call to validate findings and coordinate response; and
Mobilize internal teams and notify external stakeholders as needed.
[Note: If event categorization will help identify different response strategies, then a section can be inserted here to outline different event types and the specific response procedures that follow the Response Phases outlined below.]
5.2 Response Phases
An MRE will be managed in four structured phases:
Phase 1 – Customer Communication
Issue early notification to affected customers.
Provide guidance on certificate replacement timelines and procedures.
Engage technical support teams for high-priority customers.
Phase 2 – Certificate Replacement
[Important Note: Because past delayed revocation incidents have revealed that certificate replacement is often the most troublesome, complex, and time-sensitive aspect of a mass revocation event, this section of the plan must be carefully developed, with detailed procedures that address automation, customer support, prioritization of critical systems, and fallback strategies. The CA operator should ensure that this part of the plan accounts for potential bottlenecks, customer challenges, and any necessary tooling improvements to facilitate timely replacement and certificate revocation.]
Automate renewal or reissuance where possible.
Offer manual assistance for complex cases.
Monitor progress and address replacement delays.
Phase 3 – Certificate Revocation
Execute mass revocation in compliance with industry timelines.
Publish updated CRLs and OCSP responses within expected timeframes.
Report delayed revocations if necessary.
Phase 4 – Post-Mortem and Improvement
Conduct an internal review of response effectiveness.
Document lessons learned and areas for improvement.
Update MRIP&TP based on findings.
6. Response Team Organization and Responsibilities
Effective execution of this plan depends on clear team roles.
6.1 Organizational Chart
7. Plan Training, Testing, and Continuous Improvement
7.1 Training and Awareness
All team members must undergo annual training on mass revocation response procedures.
Regular testing exercises will be conducted to evaluate readiness.
7.2 Training Responsibilities
The Plan Owner and Compliance Team are responsible for:
Training all relevant CA personnel on MRIP&TP execution and updates.
Providing specialized training for the Certificate Revocation, Customer Relations, and Technical Support Teams.
Ensuring that personnel understand their roles in a mass revocation event.
Conducting annual refresher training and testing exercises to maintain readiness.
7.3 Plan Testing and Simulation
The Plan Owner and Compliance Team are responsible for:
Testing the MRIP&TP (through simulations, tabletop exercises, or using controlled test environments) at least once every 12 months
Simulated revocation scenarios to assess:
Effectiveness of customer communication.
Speed and accuracy of certificate replacement.
Efficiency of revocation execution.
Team coordination and response times.
7.4 Post-Incident Review
The Plan Owner, in coordination with the Compliance Team, will:
Document testing processes, results, and remediation steps.
Conduct a post-mortem after every Mass Revocation Event or test.
Document findings and use them to update this plan.
7.5 Continuous Improvement and Plan Maintenance
The Plan Owner, in coordination with the Compliance Team, will:
Implement plan improvements based on test findings.
Update the MRIP&TP as needed based on test results, external audits, and policy changes.
Review governance processes to ensure they align with policy updates.
Maintain version control and document significant changes.
Ensure the updated plan is distributed to all relevant personnel.
8. Third-Party Assessment
In accordance with Mozilla Root Store Policy Section 6.1.3, CA Operator will:
Engage a third-party assessor annually, beginning with the CA’s next audit cycle occurring on or after June 1, 2025.
Provide documentation to the assessor demonstrating that:
The MRIP&TP is well-documented and actionable.
Testing exercises have been conducted and properly documented.
Feedback from testing has been incorporated into this plan to enhance revocation readiness.
Work with the assessor to address any gaps or findings from the assessment.
9. Conclusion
This Mass Revocation Incident Preparation and Testing Plan is a critical component of [CA Operator]’s commitment to operational resilience and compliance. By ensuring clear roles, effective response strategies, and continuous improvement, [CA Operator] will uphold trust and security in the Web PKI ecosystem.