Maybe the baseline requirements need to be updated to require an automated mechanism for reporting key compromises. CAs have to revoke certs with compromised keys, but by going out of their way to increase the barrier to doing so, they're clearly not complying in good faith.
The ACME protocol (Let's Encrypt) makes this simple - just sign a request to the revocation API with the cert's private key.
Also, customer service for dealing with the certificate holder.
That said, offering an API and automating as much as they can is a lot easier than receiving the reports through free-form e-mail, with followup through Mozilla's root program (https://wiki.mozilla.org/CA/Bug_Triage#Compliance_Problems_a...), where the CA will have to take action or cease existing.
It would have been nice to have names be named. This is obviously in bad faith, and the bad actors should be called out.
Given that Matt Palmer is an active participant of the MDSP (Mozilla Dev Security Policy) mailing list, I am surprised that I don't recall seeing discussion about this pop up, although I may have missed it. The CAs acting this way really should have to explain themselves.
Lets encrypt has this. https://letsencrypt.org/docs/revoking/#using-the-certificate...
https://pwnedkeys.com/submit.html
Which if you had an standardized representation of that attestation, maybe CAs could consume that instead.
But, the author of pwnedkeys thought of that, and started an RFC for exactly that:
https://github.com/pwnedkeys/key-compromise-attestation-rfc/...
But it seems dead right now.
If this is most feasible, ok, though it smells like the opposite of responsible disclosure. Perhaps I'm just not in tune with the nature of how this threat differs from a typical software vulnerability, and therefore the responsible disclosure method I'm familiar with is irrelevant.
He's not sharing the key itself, just proof that it's been leaked. Unlike disclosing a security issue without warning, this disclosure doesn't give any bad actors and power they didn't already possess. (Because any bad actors who have the key would already know what TLS certs it matches, or could trivially find out by querying CT logs themselves.)
Responsible disclosure is a courtesy that should not be extended to bad faith actors.
Read: https://adamcaudill.com/2015/11/19/responsible-disclosure-is...