We maintain a rather large number (tens of thousands) of certificates on behalf of our customers, and we’re switching our workflow to use Certbot as an Acme client to create and renew certificates. (We don’t need Certbot to manage renewals, we just use it to interact with Let’s Encrypt.)
It would be much simpler for us to not keep track of the private keys needed for renewal requests, and to instead request brand new certificates every three months.
We want to be respectful users of this great service, so we’re wondering if this is okay with Let’s Encrypt (subject to rate limits of course).
So, you’re just planning to issue the new certificates with a different private key instead of the same private key? That’s already the default behavior of Certbot and is totally unobjectionable.