Sorry for showing up here unannounced.

This is a very strange claim. I'm not speaking in any official capacity but at
least __personally__ being at the Linux Systems Group at MSFT I've never have
encountered any hard requirement on grub.

In any case, I want to point out a few things:

* Some of the signing requirements as expressed here afaict:
  
https://techcommunity.microsoft.com/t5/hardware-dev-center/updated-uefi-signing-requirements/ba-p/1062916
  and it mentions:

  > If your submission is a SHIM (handing off execution to another
  > bootloader), then you must first submit to the SHIM review board and be
  > approved before a submission will be signed. [...]".

  I don't see any requirement that suggeste MSFT would require a specific boot
  loader.

* MSFT recently published
  
https://docs.microsoft.com/en-us/windows/security/information-protection/secure-the-windows-10-boot-process
  and states

  > The default state of Secure Boot has a wide circle of trust which can result
  > in customers trusting boot components they may not need. Since the Microsoft
  > 3rd Party UEFI CA certificate signs the bootloaders for all Linux
  > distributions, trusting the Microsoft 3rd Party UEFI CA signature in the 
UEFI
  > database increases the attack surface of systems. A customer who intended to
  > only trust and boot a single Linux distribution will trust all distributions
  > – much more than their desired configuration. A vulnerability in any of the
  > bootloaders exposes the system and places the customer at risk of exploit 
for
  > a bootloader they never intended to use, as seen in recent vulnerabilities,
  > for example with the GRUB bootloader or firmware-level rootkit affecting 
boot
  > components. Secured-core PCs require Secure Boot to be enabled and 
configured
  > to distrust the Microsoft 3rd Party UEFI CA signature, by default, to 
provide
  > customers with the most secure configuration of their PCs possible.

  This explicitly mentions the security track record of GRUB as one of the
  reasons for making this - let's keep it civil and call it controversial -
  decision of disabling the 3rd part signing key in the BIOS.

* The shim-review repo did approve a shim plus another boot loader for CISCO
  multiple times. For example,
  https://github.com/rhboot/shim-review/issues/212

  > We have no plans to use GRUB2 as a second stage loader. Our intention is to
  > bundle the Linux Kernel, initramfs, and kernel command line into a single 
EFI
  > binary such that the PE/COFF signature protects all of those components. We
  > are using a small EFI stub, based on the systemd-boot stub, to do this and 
we
  > have augmented it to add support for a SBAT section. The "stubby" EFI shim:
  > https://github.com/puzzleos/stubby

  So just to be very clear their stubby boot loader is a standalone
  systemd-boot clone...

In light of all this quotes like:

https://github.com/rhboot/shim/issues/472#issuecomment-1118529154:

> grub is the only 2nd stage loader that is allowed to be signed with the shim
> MS trust chain, so it's a bit pointless.

and

https://github.com/rhboot/shim/issues/472#issuecomment-1118628769

> Regarding bootloader signing: grub is being signed, signing any additional
> bootloader increases the attack surface, hence only grub will be signed (the
> exception is that you can load a kernel directly; you can combine the kernel
> with systemd-boot stub too, as the entire binary is signed - however,
> systemd-boot stub is becoming increasingly complex (e.g. sysexts) and at some
> point one might have to pull the plug on that too and use a fork of an older
> version).
> 
> Note that we only have talked about distributions that already ship grub
> bootloader. We have not discussed signing alternative bootloaders for new
> distributions without grub; however, at least systemd-boot and pxelinux are
> barred from signing in general due to implementation quality concerns
> fundamental disagreement about how secure boot works.
> 
> e.g. if you sign systemd-boot or pxelinux with your key inside the shim, your
> next shim review will be rejected

Especially "systemd-boot stub is becoming increasingly complex" and "due to
implementation quality concerns" is mind-blowlingly ironic and frankly
disingenuous.
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