[Cscwg-public] Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

Tue Nov 16 00:13:52 UTC 2021

Hi Ian,

I think that we may have to think of reuse of some of the validation data.

If the Subscriber is to provide an IT audit, I assume that this would not be required for each key. I would think that the CA needs a Subscriber audit and warranty that all keys would be generated on the HSM covered by the IT audit.

This would also apply to the Cloud subscription agreement as the subscription agreement should be allowed to be reused for more than one key. This will allow the Subscriber to use keys for short periods of time and have no issues with certificate renewal or reissue. If we do not allow reuse, then the Subscriber would just be providing the same subscription agreement over and over again.

We could limit the reuse to no greater than 39 months, which is the maximum validity of a Code Signing certificate. We might also want to reduce the reuse to another value such as 398-days similar to the SSL BRs.

Other methods would not need a reuse period as they would be validated per key such a pre-installed key or key attestation. I also assume that the Signing Service would not need reuse if the Signing Service was operated by the CA.

Thanks, Bruce.

From: Ian McMillan <ianmcm at microsoft.com>
Sent: Thursday, November 11, 2021 8:36 AM
To: Ian McMillan <ianmcm at microsoft.com>; cscwg-public at cabforum.org; Bruce Morton <Bruce.Morton at entrust.com>
Subject: [EXTERNAL] RE: Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

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Hi Folks,

After a brief side conversation with Bruce, I’ve made some further edits to the redline draft to include the CA prescribed CSP and suitable hardware crypto module scenario raised in the last call.

Please review the attached redline now and let me know if you have any feedback and if you are willing to endorse this ballot.

Thanks,
Ian

From: Cscwg-public <cscwg-public-bounces at cabforum.org<mailto:cscwg-public-bounces at cabforum.org>> On Behalf Of Ian McMillan via Cscwg-public
Sent: Tuesday, November 9, 2021 8:35 AM
To: Bruce Morton <Bruce.Morton at entrust.com<mailto:Bruce.Morton at entrust.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>
Subject: [EXTERNAL] Re: [Cscwg-public] Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

Thanks Bruce!

Really appreciate the help with the new redline draft. I’ve added the effective date of September 1, 2022 for this change to private key protection requirements. That seems reasonable and better than placing a date closer to major events in the calendar year (e.g. end of year holiday season).

The other thing that isn’t sitting well with me is the Signing Service requirements section 16.2, so I added the cloud-based key protection to the list of techniques that MAY be used for protecting the private keys of subscribers in a Signing Service. I know this section will have considerable overhauling in the very near future, so I only would like to add this minor update.

For everyone, please see that new attached redline now. Also please let me know if you are willing to endorse the ballot.

Thanks,
Ian

From: Bruce Morton <Bruce.Morton at entrust.com<mailto:Bruce.Morton at entrust.com>>
Sent: Thursday, November 4, 2021 3:00 PM
To: Bruce Morton <Bruce.Morton at entrust.com<mailto:Bruce.Morton at entrust.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>; Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>
Subject: [EXTERNAL] RE: Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

Hi Ian,

Great meeting. Looks like we are making progress now. It will be nice to get this behind us.

Since the change will impact the CAs, we need the ballot to have an effectivity date. As such, we need to keep the current requirements as is with no change. We will also add in the new requirements and have them be effective on a future date. It is understood that the CAs may implement the requirement before that date.

Attached is a draft with the idea. I used the latest version of the CSBRs and captured most of the changes.

It would be great, if the CAs could provide some feedback on an effective date.

Thanks, Bruce.

From: Cscwg-public <cscwg-public-bounces at cabforum.org<mailto:cscwg-public-bounces at cabforum.org>> On Behalf Of Bruce Morton via Cscwg-public
Sent: Wednesday, November 3, 2021 1:21 PM
To: Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>
Subject: [EXTERNAL] Re: [Cscwg-public] Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

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Hi Ian,

Thanks for the proposal. Please find your document with some edits. I wanted to state that the subscriber could use a Signing Service to protect the private key. In addition I tried to reduce the number of “FIPS 140-2 Level 2 or Common Criteria EAL 4+” call outs as I am sure they will not remain consistent.

Looking forward to the discussion tomorrow.

Thanks again, Bruce.

From: Cscwg-public <cscwg-public-bounces at cabforum.org<mailto:cscwg-public-bounces at cabforum.org>> On Behalf Of Ian McMillan via Cscwg-public
Sent: Wednesday, November 3, 2021 10:58 AM
To: cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>
Subject: [EXTERNAL] [Cscwg-public] Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

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Hi Folks,

I’ve found the time to write up the subscriber private key protection update under a proposed Ballot CSC-6. Please review the attached redline doc and provide feedback. Also, please let me know if you are willing to endorse this ballot.

cscwg:csc_6_-_update_to_subscriber_private_key_protection_requirements [CAB Forum Wiki]<https://urldefense.com/v3/__https:/nam06.safelinks.protection.outlook.com/?url=https*3A*2F*2Furldefense.com*2Fv3*2F__https*3A*2Fwiki.cabforum.org*2Fcscwg*2Fcsc_6_-_update_to_subscriber_private_key_protection_requirements__*3B!!FJ-Y8qCqXTj2!JFXFBvuicNpp5JGeK1TvRJ-6eotM5fhSRjTUe2CUTty2HljPYkdltIcLdAbGX374fBk*24&data=04*7C01*7Cianmcm*40microsoft.com*7Ccc354d4529b4414011a408d9a385cb2d*7C72f988bf86f141af91ab2d7cd011db47*7C0*7C0*7C637720617753249627*7CUnknown*7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0*3D*7C1000&sdata=9TMurjkZZoqTbBZgq20*2Bc1Y5qv*2FmOUOhb*2FJ8x6iyzvY*3D&reserved=0__;JSUlJSUlJSUlJSUlJSUlJSUlJSUlJSUlJSUl!!FJ-Y8qCqXTj2!O-PiNIMb_VPnPjThUo5WvU8k9DUAyho2fGNbCLxiL9RGvvVd-huA12f07v0rVLQ8aJA$>
Ballot CSC-6: Update to Subscriber Private Key Protection Requirements
Purpose of this ballot: Update the subscriber private key protection requirements in the Baseline Requirement for the Issuance and Management of Publicly-Trusted Code Signing Certificates v2.5. The following motion has been proposed by Ian McMillan of Microsoft, and endorsed by <Name + Org> and <Name + Org>.

- MOTION BEGINS - This ballot updates the “Baseline Requirements for the Issuance and Management of Publicly‐Trusted Code Signing Certificates“ version 2.5 according to the attached redline which includes:

  *   Update section 16.3 “Subscriber Private Key Protection” to “Subscriber Private Key Protection and Verification”
  *   Update section 16.3 “Subscriber Private Key Protection” to include sub-sections “16.3.1 Subscriber Private Key Protection” and “16.3.2 Subscriber Private Key Verification”
  *   Update section 16.3 under new sub-section 16.3.1 to remove allowance of TPM key generation and software protected private key protection, and remove private key protection requirement differences between EV and non-EV Code Signing Certificates
  *   Update section 16.3 under new sub-section 16.3.1 to include the allowance of key generation and protection using a cloud-based key protection solution providing key generation and protection in a hardware crypto module that conforms to at least FIPS 140-2 Level 2 or Common Criteria EAL 4+
  *   Update section 16.3 under new sub-section 16.3.2 to include verification for Code Signing Certificates' private key generation and storage in a crypto module that meets or exceeds the requirements of FIPS 140-2 level 2 or Common Criteria EAL 4+ by the CAs. Include additional acceptable methods for verification including cloud-based key generation and protection solutions and a stimpulation for CAs to satisfy this verification requirement with additional means specified in their CPS. Any additional means specified by a CA in their CPS, must be proposed to the CA/Browser Forum for inclusion into the acceptable methods for section 16.3.2 within 6 months of inclusion in their CPS.
- MOTION ENDS -

The procedure for approval of this ballot is as follows:
Discussion (7 days) Start Time: TBD End Time: TBD
Vote for approval (7 days) Start Time: TBD End Time: TBD

Thanks,
Ian
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