My recollection from various CA/Browser discussions is that CAs are *not*
actually required to keep around CSRs.  Am I wrong?

Most CAs do, because it is the easiest way to log proof of possession of the
private key, and because it is useful for a variety of other auditing
activities, but other methods are possible, in principle.

In fact, I'm struggling to even find that requirement --- 3.2.1 is empty in
the latest copy of the BRs.  CSRs are only mentioned in an obscure footnote
about potential methods for calculating Request Tokens.

-Tim

-----Original Message-----
From: Acme [mailto:acme-boun...@ietf.org] On Behalf Of Jacob Hoffman-Andrews
Sent: Thursday, November 30, 2017 3:44 PM
To: Richard Barnes <r...@ipv.sx>; Daniel McCarney <c...@letsencrypt.org>
Cc: Logan Widick <logan.wid...@gmail.com>; ACME WG <acme@ietf.org>
Subject: Re: [Acme] Question about the new finalizeURL approach, and the
order object format after finalizeURL

On 11/30/2017 02:34 PM, Richard Barnes wrote:
> As Jacob points out, CAs are already required to keep around CSRs in 
> audit logs.

You missed an important nuance: CAs are not required to keep around CSRs in
an online database for live querying on the web. It is much more expensive
to store a CSR in a performant database than a rarely-accessed log.

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