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Logging (for Certificate Transparency) isn't a policy requirement. In fact last time I looked, there are (special purpose, typically in industrial settings so their clients aren't web browsers) Intermediates under some roots that just aren't outfitted to be capable of logging at all. Their existence is not a policy violation.

Clients (most particularly, popular browsers such as Chrome) can and do require SCTs (effectively proof the certificate was logged) to accept a certificate, but that just means if you issue a certificate under a trusted root without logging it, it just won't work in such browsers until somebody logs it.

You can even do this intentionally, if you're Google for example you get yourself (unlogged) certificates for shiny-new-product.google.example and shiny-new-product.example on Monday, and you don't need to worry that some eagle-eyed journalist spots that in the logs before your official product launch on Thursday evening, live in front of millions of people. You can log the certificate yourself minutes before launch, then attach the SCTs and it'll work.

[Google even got this wrong once, mistakenly using a certificate they didn't have enough SCTs for due to a bug. Chrome rejected these certificates and so, for a brief period until they fixed the problem, Google's own sites didn't work in Chrome]

Now, that last part is technically not trivial to do correctly (chances are your existing web dev tooling can't do SCT stapling, or at least you'd need to go read a bunch of instructions that you aren't going to bother with) and so when you get a Let's Encrypt cert, or you buy something cheap from a reseller, it is already logged for you, the SCTs are baked inside the certificate you get -- but that's just because there isn't a big market for unlogged certificates, not because such certificates can't or mustn't exist.




Thanks, I didn’t know it’s not a requirement. Hopefully it’ll be a requirement for every CA in the future.




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