The order of renewals and new certificate issuance is no longer important for the renewal exemption since July 20th, 2017.
Has this actually been implemented? In the last 168 hrs I generated 4 new certificates, and renewed 16. I tried to issue a new certificate and I got error 429: “too many certificates already issued for…”
Each certificate has a common name and 6 SANs, which are 6 unique sub-domain, 4 of which are on a different TLD. For example: https://crt.sh/?id=187348881
Why am I hitting the 20 limit?