[Cscwg-public] [External Sender] Re: Timestamp Certificate and SubCA updates

Adriano Santoni adriano.santoni at staff.aruba.it
Thu Apr 4 06:36:04 UTC 2024


+1

Il 04/04/2024 04:20, Mohit Kumar via Cscwg-public ha scritto:
>
> Hi Martijn,
>
> Can I confirm that the proposal to protect private keys of Subordinate 
> CAs in an offline state is applicable to only private keys generated 
> for Roots/Subordinate CAs created after the effective date.
>
> Also, per my understanding, the scope of the proposal is limited 
> to only Root/Subordinate CAs issuing Timestamp Certificates for Code 
> Signing (i.e. with the OID 2.23.140.1.4.2). If yes, may be it would be 
> better to clarify the same with the following language update
>
> ‘Effective April 15, 2025, a Timestamp Authority MUST protect Private 
> Keys associated with its Root CA certificates and Subordinate CA 
> certificates containing the `id-kp-timeStamping` KeyPurposeId in the 
> `extKeyUsage` extension (per section 7.1.2.2 g) and that issued 
> Timestamp Certificates with the policyidentifier 2.23.140.1.4.2, in a 
> Hardware Crypto Module conforming to the requirements specified in 
> [Section 6.2.7.1](#6271-private-key-storage-for-CA-keys), maintained 
> in a High Security Zone and in an offline state or air-gapped from all 
> other networks.’
>
> Thanks
>
> Mohit
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org> *On Behalf Of 
> *Martijn Katerbarg via Cscwg-public
> *Sent:* Tuesday, March 19, 2024 5:04 AM
> *To:* cscwg-public at cabforum.org; Dimitris Zacharopoulos (HARICA) 
> <dzacharo at harica.gr>
> *Subject:* Re: [Cscwg-public] Timestamp Certificate and SubCA updates
>
> The language (https://github.com/cabforum/code-signing/pull/34 ) has 
> been further updated 
> (https://github.com/cabforum/code-signing/pull/34/commits/9288f7ec376b4bbd139dcb596bcb2d1bf9bd7683) 
> based on the below. @Dimitris Zacharopoulos (HARICA) 
> <mailto:dzacharo at harica.gr> I replaced “deleted” with “destroyed” in 
> your proposal, as I believe it would fit better in that section.
>
> Are there any further comments? If not I will start the official 
> discussion period in the next few days.
>
> Regards,
>
> Martijn
>
> *From: *Cscwg-public <cscwg-public-bounces at cabforum.org> on behalf of 
> Martijn Katerbarg via Cscwg-public <cscwg-public at cabforum.org>
> *Date: *Monday, 11 March 2024 at 09:51
> *To: *Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>, 
> cscwg-public at cabforum.org <cscwg-public at cabforum.org>
> *Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates
>
> CAUTION: This email originated from outside of the organization. Do 
> not click links or open attachments unless you recognize the sender 
> and know the content is safe.
>
> Works for me on both fronts. I’ll leave the discussion open for a bit 
> so others can add on.
>
> *From: *Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>
> *Date: *Monday, 11 March 2024 at 09:48
> *To: *Martijn Katerbarg <martijn.katerbarg at sectigo.com>, 
> cscwg-public at cabforum.org <cscwg-public at cabforum.org>
> *Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates
>
> CAUTION: This email originated from outside of the organization. Do 
> not click links or open attachments unless you recognize the sender 
> and know the content is safe.
>
> On 11/3/2024 10:32 π.μ., Martijn Katerbarg wrote:
>
>     Thanks Dimitris, I’ve reviewed and accepted the suggestions.
>
>     > witnessed by members of two different Trusted Roles (not by two Trusted Role
>     Members, i.e. you can't use two persons of the same Trusted Role).
>
>     TBH, I’m not sure why it couldn’t be two persons of the same
>     Trusted Role?
>
>
> I'm not a native English speaker but I think "Roles" (plural) points 
> to the different types of Roles, while "Trusted Role members" would 
> point to different Members in any Trusted Role. If the intent is to 
> have a 4-eye principle control from any Trusted Role, we can make it 
> clearer by using the "Trusted Role members" phrase.
>
>     > In general, a "key destruction" ceremony includes the deletion of all copies
>     of the key, including copies that reside in backups. If we require
>     a "key destruction" ceremony, the "restore key" case is
>     nonsensical. We probably need to work on this some more so that we
>     all have the same understanding and expectations.
>
>     > It's ok to keep the keys in backups but if you happen to restore them in an
>     HSM, you must not use them to sign anything. If a CA/TSA can also
>     "destroy" the key, meaning that all copies of that private key can
>     be unequivocally/securely deleted (i.e. without a way to recover
>     the key), including any instance of the key as part of a backup,
>     the better!
>
>     Agreed in general regarding the Key Destruction ceremony. However
>     having to also destroy the backup of the key, and do this again
>     for any next key every 18 months, can be a lengthy procedure,
>     specially if backups are stored securely and offline in different
>     places around the world. That’s why for this case we specifically
>     call out that backups don’t need to be destroyed.
>
>     But your point on an HSM restoring an entire partition and that
>     violating the requirement, is valid.
>
>     For reference, the current proposed language is:
>
>     /The CA MAY maintain existing backup sets containing the Private
>     Key corresponding to a Timestamp Certificate. The CA MUST NOT
>     restore the Private Key corresponding to a Timestamp Certificate
>     contained within the backup if the Timestamp Certificate was
>     issued more than 15 months prior to restoration of the backup./
>
>     //
>
>     What about we once more use the NSR language and state:
>
>     /The CA MAY maintain existing backup sets containing the Private
>     Key corresponding to a Timestamp Certificate. The CA SHOULD NOT
>     restore the Private Key corresponding to a Timestamp Certificate
>     contained within the backup if the Timestamp Certificate was
>     issued more than 15 months prior to restoration of the backup. If
>     the CA does restore such a Private Key, the CA SHALL only restore
>     the Private Key in a suitable HSM while it’s maintained in a High
>     Security Zone and in an offline state or air-gapped from all other
>     networks and perform a new key destruction ceremony prior to the
>     HSM being brought to an online state./
>
>     //
>
>     Thoughts?
>
>
> If we want to allow the existence of a key in a backup, IMHO we should 
> avoid using the "key destruction" language. How about the following:
>
> Modify
>
>     /For Timestamp Certificates issued on or after June 1, 2024, the
>     CA SHALL log the removal of the Private Key from the Hardware
>     Crypto Module through means of a key destruction ceremony
>     performed by the CA and witnessed and signed-off by at least two
>     Trusted Roles./
>
>
> to
>
>     /For Timestamp Certificates issued on or after June 1, 2024, the
>     CA SHALL log the removal of the Private Key from the Hardware
>     Crypto Module through means of a key deletion ceremony performed
>     by the CA and witnessed and signed-off by at least two Trusted
>     Role members. The CA MAY also perform a key destruction ceremony,
>     /meaning that all copies of that private key are
>     unequivocally/securely deleted (i.e. without a way to recover the
>     key), including any instance of the key as part of a backup, to
>     satisfy this requirement.
>
>
> Thanks,
> Dimitris.
>
>     //
>
>     As a side-note, I wonder if there’s a task for the NSWG (or
>     Definitions WG once it’s setup) to define terms for online and
>     offline HSMs
>
>     *From: *Cscwg-public <cscwg-public-bounces at cabforum.org>
>     <mailto:cscwg-public-bounces at cabforum.org> on behalf of Dimitris
>     Zacharopoulos (HARICA) via Cscwg-public
>     <cscwg-public at cabforum.org> <mailto:cscwg-public at cabforum.org>
>     *Date: *Sunday, 10 March 2024 at 10:30
>     *To: *cscwg-public at cabforum.org <cscwg-public at cabforum.org>
>     <mailto:cscwg-public at cabforum.org>
>     *Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates
>
>     CAUTION: This email originated from outside of the organization.
>     Do not click links or open attachments unless you recognize the
>     sender and know the content is safe.
>
>     Hi Martijn,
>
>     Two suggestions submitted on GitHub.
>
>     Regarding the prohibition of restoring a private key of a
>     Timestamp Certificate, I'm not sure how universal this can be
>     because some HSMs restore an entire slot/partition, which might
>     contain Private Keys associated with obsolete Timestamp
>     Certificates. As the ballot is written, such an action would be a
>     violation.
>
>     In general, a "key destruction" ceremony includes the deletion of
>     all copies of the key, including copies that reside in backups. If
>     we require a "key destruction" ceremony, the "restore key" case is
>     nonsensical. We probably need to work on this some more so that we
>     all have the same understanding and expectations.
>
>     Let me restate the intent of this requirement as discussed all
>     this time, and please correct me if I'm wrong.
>
>     IMO, the goal is to put the keys associated with Timestamp
>     Certificates out of use, 15 months after the /notBefore /of the
>     Timestamp Certificate.
>
>     In order to achieve some level of assurance for this action, the
>     proposal is to delete the keys from the HSM 18 months after the
>     /notBefore /of the Timestamp Certificate, in an audited way,
>     witnessed by members of two different Trusted Roles (not by two
>     Trusted Role Members, i.e. you can't use two persons of the same
>     Trusted Role).
>
>     It's ok to keep the keys in backups but if you happen to restore
>     them in an HSM, you must not use them to sign anything. If a
>     CA/TSA can also "destroy" the key, meaning that all copies of that
>     private key can be unequivocally/securely deleted (i.e. without a
>     way to recover the key), including any instance of the key as part
>     of a backup, the better!
>
>     Thoughts?
>
>     Dimitris.
>
>     On 6/3/2024 2:07 μ.μ., Martijn Katerbarg via Cscwg-public wrote:
>
>         All,
>
>         As discussed last week, I’d send out the draft language for
>         this ballot once more before starting the discussion period. 
>         The latest version can be found in
>         https://github.com/cabforum/code-signing/pull/34
>
>         I’ve made changes this morning to add 3 effective dates, these
>         are:
>
>           * For the removal of private keys associated with timestamp
>             certificates, effective June 1^st , 2024, CAs will need to
>             properly log the removal of said key.
>
>               o While I expect CAs to already properly log this for
>                 audit purposes even now, there may be exceptions for
>                 when this has not been done,  for example a private
>                 key or timestamp certificate that was signed maybe 20
>                 years ago. This language is added to avoid any
>                 confusion on from what point there needs to be an
>                 audit trail
>
>           * Effective April 15, 2025, private keys associated with
>             SubCAs containing the “Time Stamping” EKU will need to be
>             placed in offline HSMs.
>
>               o I believe a roughly one year effective date is
>                 appropriate here, since CAs may need to move keys from
>                 one HSM to another.
>
>           * For private keys associated with timestamp certificates
>             that were issued for greater than 15 months, CAs will need
>             to remove the private keys 18 months after certificate
>             issuance, starting April 15, 2025.
>
>               o Likewise, I feel like anything involving HSM process
>                 changes, should have a longer effective date, and it
>                 makes sense to align this with the effective date above.
>
>         I’ll start a ballot on this early next week, unless there is
>         concern with the above.
>
>         Regards,
>
>         Martijn
>
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