CAs serve a privileged and trusted role on the internet that underpin encrypted connections between browsers and websites. With this tremendous responsibility comes an expectation of adhering to reasonable and consensus-driven security and compliance expectations, including those defined by the CA/Browser Forum TLS Baseline Requirements. Over the past several months and years, we have observed a pattern of compliance failures, unmet improvement commitments, and the absence of tangible, measurable progress in response to publicly disclosed incident reports. When these factors are considered in