[Cscwg-public] [EXTERNAL] Re: Re FIPS tokens supporting RSA 3072

Tomas Gustavsson tomas.gustavsson at primekey.com
Fri Mar 19 10:23:24 UTC 2021

On 2021-03-19 10:44, Adriano Santoni via Cscwg-public wrote:
> Let me clarify that I am not trying to delay the key size effective 
> date. I just wanted to bring to the WG's attention that the said 
> requirement implies sourcing devices from a single supplier, which is 
> bad thing competition-wise.
> I'd love to hear from the other folks here, what do they think. If it's 
> a "no problem", so much the better (or worse).
> If Tomas' interpretation of CSBR §16.3 (item 2) is shared by most WG 
> members (or at least by those who have an opinion on it), the problem 
> lessens a bit, although it certainly does not go away.

It wasn't my interpretation of 16.3 (I'm just an interested party). As 
16.3 is (deliberately?) vaguely written with regards to the common 
criteria clause, I just highlighted what could be one possible 
As you very nicely noted, there are many protection profiles that 
fulfill 16.3 as written. If the CSBRs don't supply any guidance, I guess 
it's down to auditors to decide how to interpret it?
Common Criteria is so much harder to navigate than FIPS, rabbit holes 

My hunch is that that the Nitro token is just as good, and secure, as 
the eToken, to use for code signing purposes in practice.


> Thanks,
> Adriano
> Il 17/03/2021 21:42, Ian McMillan ha scritto:
>> Hi Folks,
>> This key size effective date has already been delayed by 6 months. I 
>> am not keen on further delaying the requirement of 3072 keys for RSA 
>> due to a lack of tokens that support the requirement in the CSBRs. As 
>> Bruce calls out, there are other means to which subscribers can secure 
>> their private keys to meet the requirements outside of a token 
>> provided by a CA. If this change in key size is what pushes 
>> subscribers to use HSMs (on-prem or cloud based services) or signing 
>> services, it may serve as the call to action for token suppliers on a 
>> requirement they have frankly seemed to have overlooked for some time 
>> now.
>> I’ll be interested to discuss how much additional time the group feels 
>> is needed here, and how best we can help accelerate the transition.
>> Thanks,
>> Ian
>> *From:* Cscwg-public <cscwg-public-bounces at cabforum.org> *On Behalf Of 
>> *Adriano Santoni via Cscwg-public
>> *Sent:* Wednesday, March 17, 2021 9:31 AM
>> *To:* Bruce Morton <Bruce.Morton at entrust.com>
>> *Cc:* cscwg-public at cabforum.org
>> *Subject:* Re: [Cscwg-public] [EXTERNAL] Re: Re FIPS tokens supporting 
>> RSA 3072
>> Hi Bruce,
>> I certainly agree that - if the said token is the only device 
>> available on the market meeting the said requirement, as it seems to 
>> be the case -- we should promptly revise the effective date (June 1st, 
>> just three months from now) of the transition to 3072 bits being 
>> mandatory for RSA keys.
>> If nothing else, because it would be a really bad thing to impose a 
>> requirement that involves sourcing devices from a single possible 
>> supplier, thereby favouring a monopoly. I hope everyone agrees on this 
>> principle.
>> Adriano
>> Il 17/03/2021 16:45, Bruce Morton ha scritto:
>>     Hi Adriano,
>>     We should discuss this issue at the next meeting. I do think that
>>     there are options to using the SafeNet token, but that might
>>     include subscriber hosted HSM, public-cloud HSM or Signing Service
>>     HSM.
>>     I think we all understand that the options might be hard to
>>     implement before 1 June 2021 deadline.
>>     Bruce.
>>     *From:* Cscwg-public <cscwg-public-bounces at cabforum.org>
>>     <mailto:cscwg-public-bounces at cabforum.org> *On Behalf Of *Adriano
>>     Santoni via Cscwg-public
>>     *Sent:* Wednesday, March 17, 2021 11:18 AM
>>     *To:* cscwg-public at cabforum.org <mailto:cscwg-public at cabforum.org>
>>     *Subject:* [EXTERNAL] Re: [Cscwg-public] Re FIPS tokens supporting
>>     RSA 3072
>>     WARNING: This email originated outside of Entrust.
>>     DO NOT CLICK links or attachments unless you trust the sender and
>>     know the content is safe.
>>     ------------------------------------------------------------------------
>>     I should have written "the only CC token", as the FIPS version of
>>     the said token does not support RSA > 2048 bit....
>>     But my question remains (after replacing "FIPS" with "CC").
>>     Adriano
>>     Il 17/03/2021 16:08, Adriano Santoni via Cscwg-public ha scritto:
>>         I already posted this question yesterday, but apparently it
>>         did not get through.
>>         I was asking: is the SafeNet eToken 5110 CC the only FIPS
>>         token supporting RSA 3072 available on the market?
>>         I am investigating this matter myself, and although I am not
>>         finished it seems there aren't many... possibly just one.
>>         If so, it would be a rather unfortunate situation
>>         competition-wise.
>>         Adriano
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