We theoretically could, but those certificates would show up in CT logs. (For quick & easy monitoring, you can get an RSS feed for your domain on https://crt.sh/, but it's not the most reliable service.) It would be a reputation killer if we did that, just like it would be for your DNS provider or ISP.

Right, but if you want people to trust you, you need to be open about what people are trusting you with. Your original answer seemed obfuscatory.

Sorry, not trying to obfuscate anything, hopefully this clarifies: users trust us to hold their ACME account key and we only ask for DNS records prefixed with `_acme-challenge.` to be CNAME delegated.

With this we could issue or revoke a new certificate, but we couldn't impersonate them because we don't control the rest of their DNS.

> we couldn't impersonate them because we don't control the rest of their DNS.

If that were true, nobody would need signed certificates in the first place.