[Cscwg-public] Proposal to make changes to revocation based on malware
Dimitris Zacharopoulos (HARICA)
dzacharo at harica.gr
Tue Jan 24 15:24:31 UTC 2023
On 24/1/2023 11:47 π.μ., Martijn Katerbarg wrote:
>
> Thanks for the proposal Dimitris.
>
> I have a few remarks on this:
>
> “/The CA SHALL request the Subscriber to respond with an impact
> assessment of affected Relying Parties if the revocation date is set
> before the time that the Private Key became compromised or likely used
> to sign Suspect Code, and to state the associated Application Software
> Supplier(s).”/
> I’d like to propose we change this into:
> “/The CA SHALL request the Subscriber to respond with an
> acknowledgement and SHOULD request the Subscriber to respond with an
> impact assessment of affected Relying Parties if the revocation date
> is set before the time that the Private Key became compromised or
> likely used to sign Suspect Code, and to state the associated
> Application Software Supplier(s)./”
>
> This offers CA’s the option not to request an impact assessment if
> they deem the evidence clear enough warranting revocation right away.
>
There is nothing preventing the CA to revoke a certificate right away.
Revoking a certificate *at current time* has absolutely no impact on
existing signed malware. The impact assessment affects cases of
backdating the revocation. I'm afraid this "SHOULD" is just going to be
ignored, unless you feel that the CA has enough evidence to backdate
revoke a certificate and does not want to wait for an impact assessment
of affected Relying Parties by the Subscriber. If it's the latter, I
agree but we need to write it a bit clearer.
> I’m also wondering on the interpretation of the following 2 clauses:
>
> “/2. Based on the feedback received, the CA MAY determine a more
> appropriate revocation date to be associated with the revocation of
> the Certificate./
>
> /3. The CA SHALL revoke the Certificate within 7 days after the CA
> received the Certificate Problem Report./”
>
> I like to think this means that even with a plan submitted to the
> Application Software Suppliers, revocation MUST occur no later than 7
> days after the CPR was received. Is that what you also intend here?
>
Yes. 7 days seem reasonable to pause the revocation process waiting for
a response from the Application Software Supplier but IMO no more than that.
>
> In my option that should be the maximum time before revocation needs
> to happen, however, it feels like the whole impact assessment may be a
> lot of work for a Subscriber, in order to only get 48 hours of extra
> time before a revocation needs to happen (Although to be fair these
> may be the very few edge cases, for which it could be useful).
>
> Thoughts?
>
We may need some more feedback from CAs that have actually experienced
such cases. From my perspective, 48 hours for an quick impact
assessment, seems reasonable considering the impact of a malware to
millions of users worldwide that could be stopped by a single backdate
revocation action from the CA.
Thanks,
Dimitris.
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org> *On Behalf Of
> *Dimitris Zacharopoulos (HARICA) via Cscwg-public
> *Sent:* Thursday, 15 December 2022 14:27
> *To:* cscwg-public at cabforum.org
> *Subject:* Re: [Cscwg-public] Proposal to make changes to revocation
> based on malware
>
> 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 12/15/2022 11:59 AM, Martijn Katerbarg via Cscwg-public wrote:
>
> All,
>
> We had a good discussion on the malware proposal during the last
> call. I believe we’re nearly there. Trevoli and Tim you had
> suggestions (and thank you Dean for spelling it out in the
> minutes!) to make is more clear and also allow for the exceptional
> cases where revoking a CS cert would do more damage then not.
>
> Based on this, it seems we were leaning into making the following
> changes:
>
>
> Change:
>
> a. If the Subscriber responds within 72 hours, the CA and
> Subscriber MAY determine a "reasonable date" to revoke the
> certificate. The revocation date MUST NOT be more than 7 calendar
> days after the CA received the Certificate Problem Report.
> Into:
> a. If the Subscriber responds within 72 hours, the CA MAY
> determine a "reasonable date" to revoke the certificate. The CA:
>
> 1.MUST revoke the certificate no later than 7 calendar days after
> the CA received the Certificate Problem Report; or,
>
> 2.MUST submit a plan for revocation to all Application Software
> Suppliers based on discussions with the Subscriber no later than 7
> calendar days after the CA received the Certificate Problem Report
>
>
> Thoughts on this?
> The one thought I have on this is, are Application Software
> Suppliers (i.e Certificate Consumers, but that’s not a CSCBR
> defined term) willing to take on these plans and provide responses
> to the CA?
> Cause if they don’t, it seems we again have a loop hole in which
> revocation can be done much later based upon subscriber request…
>
>
> I have the same concerns with the second bullet. And how do we
> determine "all" Suppliers? CAs have no visibility on Relying Party
> software.
>
> I believe that the reason to "contact negatively-affected Application
> Software Suppliers" is to determine the proper "reasonable date" that
> would invalidate the malware signatures and not affect other "good
> signatures" that would have a significant impact on Relying Parties.
> If there is no response from the Application Software Supplier, the CA
> should revoke with a "reasonable date" based on its investigation at
> the time.
>
> Please take a look at the following proposal. I'd appreciate feedback
> and language improvements to describe the process accurately and
> safely in order to protect Relying Parties from executing Suspect Code
> as much as possible. Worse case, CAs will revoke the Certificate with
> a revocation date set at the time of the revocation event which does
> not affect any previously signed code, including the Suspect Code
> which will be executed successfully by Relying Parties even after the
> revocation of the Certificate.
>
>
> /4.9.1.3 Revocation Based on Reported or Detected Compromise
> or Use in Suspect Code/
>
> /Except for cases that fall under Section 4.9.1.1, if, while
> investigating a Certificate Problem Report, the CA determines the
> Subscriber's Private Key is compromised or likely being used for
> Suspect Code, the CA SHALL revoke the corresponding Code Signing
> Certificate in accordance with and within the following maximum time
> frames. Nothing herein prohibits a CA from revoking a Code Signing
> Certificate prior to these time frames./
>
> 1. /The CA SHALL contact the Subscriber within 24 hours after the CA
> received the Certificate Problem Report, notifying that the
> Certificate is scheduled to be revoked with a revocation date set
> before the time that the Private Key became compromised or likely
> used to sign Suspect Code. This revocation date is set in the past
> to prevent Relying Parties from executing Suspect Code signed with
> the affected Code Signing Certificate./
> 2. /The CA SHALL request the Subscriber to respond with an impact
> assessment of affected Relying Parties if the revocation date is
> set before the time that the Private Key became compromised or
> likely used to sign Suspect Code, and to state the associated
> Application Software Supplier(s)./
> 3. /The CA SHALL request the Subscriber to respond to the CA within
> 72 hours of the CA sending the notification. /
> 4. /If the Subscriber responds within 72 hours, //then based on the
> Subscriber's impact assessment:/
> 1. /the CA MAY submit a revocation plan to associated Application
> Software Suppliers no later than 7 calendar days after the CA
> received the Certificate Problem Report. The revocation plan:/
> 1. /SHALL contain informing about the planned revocation date
> to be set for the to-be-revoked Certificate; and/
> 2. /SHALL request suggestions for a "more appropriate"
> revocation date in case the proposed revocation date has a
> significant impact on Relying Parties associated with that
> particular Application Software Supplier. /
> 3. /The CA SHALL request the Application Software Supplier to
> respond within 72 hours./
> 2. /Based on the feedback received, the CA MAY determine a more
> appropriate revocation date to be associated with the
> revocation of the Certificate./
> 3. /The CA SHALL revoke the Certificate within 7 days after the
> CA received the Certificate Problem Report./
> 5. /If the CA does not receive a response from the Subscriber, then
> the CA SHALL revoke the Certificate within 24 hours from the end
> of the response period./
>
> /A CA revoking a Certificate because the Certificate was associated
> with signed Suspect Code or other fraudulent or illegal conduct SHOULD
> provide all relevant information and risk indicators to other CAs,
> Application Software Suppliers, or industry groups. The CA SHOULD
> contact the Application Software Suppliers within 24 hours after the
> CA received the Certificate Problem Report./
>
>
> Thanks,
> Dimitris.
>
> Note: I won’t be able to attend todays call, but feel free to discuss.
>
> *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
> *Sent:* Tuesday, 29 November 2022 10:13
> *To:* cscwg-public at cabforum.org
> *Subject:* Re: [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> 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 28/11/2022 2:50 μ.μ., Martijn Katerbarg via Cscwg-public wrote:
>
> All,
>
> I just pushed a new commit
> (https://github.com/cabforum/code-signing/pull/10/commits/8e7e3b4e57960994edea267f0e753358aad99574
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F10%2Fcommits%2F8e7e3b4e57960994edea267f0e753358aad99574&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=fwiFBw8%2FI76EPcC4BH62G3gPH3NkISSWcU%2BK1EUJFy4%3D&reserved=0>)
> based on the discussions and comments I’ve had and received.
>
> The complete ballot “redline” in GitHub is available for
> review on
> https://github.com/cabforum/code-signing/pull/10/files
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F10%2Ffiles&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=YNKaeEXVYewUNLoZ3Xxeq6fCHIK8GMbVKqaErOPZXR0%3D&reserved=0>
>
>
> If the CA confirms that a Subscriber has signed "Suspect Code",
> how would the group feel with a proposal to require CAs to
> *backdate revoke* the Code Signing Certificate to a date and time
> that would neutralize the Suspect Code? If this date and time is
> unlikely to be determined, backdate revoke 1'' after the notBefore
> date and time of the Code Signing Certificate?
>
>
> Thanks,
> Dimitris.
>
>
>
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org>
> <mailto:cscwg-public-bounces at cabforum.org> *On Behalf Of
> *Martijn Katerbarg via Cscwg-public
> *Sent:* Monday, 26 September 2022 11:58
> *To:* Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>
> <mailto:dzacharo at harica.gr>; cscwg-public at cabforum.org
> *Subject:* Re: [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> 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.
>
> Thank you Dimitris. That makes sense. I’ve pushed an update to
> the draft-PR
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org> *On
> Behalf Of *Dimitris Zacharopoulos (HARICA) via Cscwg-public
> *Sent:* Friday, 23 September 2022 18:47
> *To:* cscwg-public at cabforum.org
> *Subject:* Re: [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> 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.
>
> I posted some proposed changes for consistency and accuracy.
>
> 1. https://github.com/cabforum/code-signing/pull/10#pullrequestreview-1118760785
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F10%23pullrequestreview-1118760785&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Wa8%2B%2Bsc0OyZpA%2FTF6%2B9XdGRkedLQ0fSZj1lXlSxxTg8%3D&reserved=0>
>
>
> Thanks,
> Dimitris.
>
> On 23/9/2022 3:55 μ.μ., Bruce Morton via Cscwg-public wrote:
>
> Hi Martjin,
>
> I will endorse the ballot.
>
> Thanks, Bruce.
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org>
> <mailto:cscwg-public-bounces at cabforum.org> *On Behalf Of
> *Martijn Katerbarg via Cscwg-public
> *Sent:* Friday, September 23, 2022 3:44 AM
> *To:* cscwg-public at cabforum.org
> *Subject:* [EXTERNAL] Re: [Cscwg-public] Proposal to make
> changes to revocation based on malware
>
> WARNING: This email originated outside of Entrust.
> DO NOT CLICK links or attachments unless you trust the
> sender and know the content is safe.
>
> ------------------------------------------------------------------------
>
> All,
>
> As discussed on yesterdays call, the latest changes which
> Tim and I were discussing are pushed into Github.
>
> The complete change can be found at
> https://github.com/cabforum/code-signing/pull/10/files
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F10%2Ffiles&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=YNKaeEXVYewUNLoZ3Xxeq6fCHIK8GMbVKqaErOPZXR0%3D&reserved=0>
> for review.
>
> Bruce, Ian, since I earlier had your endorsements, please
> let me know if they still stand. The changes since the
> endorsements, are captured in
> https://github.com/cabforum/code-signing/pull/10/commits/90fa38ab4dc5e5f9b25fce844b750d693f7256b7
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F10%2Fcommits%2F90fa38ab4dc5e5f9b25fce844b750d693f7256b7&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=ZxumKMoYS9YC52G8MXtYBhRMRf4sRrSfNR1nV63a55s%3D&reserved=0>
>
> If there are no other comments, then hopefully we can
> start a ballot process on this.
>
>
> Regards,
>
> Martijn
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org>
> *On Behalf Of *Martijn Katerbarg via Cscwg-public
> *Sent:* Tuesday, 19 July 2022 09:22
> *To:* Tim Hollebeek <tim.hollebeek at digicert.com>;
> cscwg-public at cabforum.org
> *Subject:* Re: [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> 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.
>
> Thanks Tim,
>
> 1. What is the motivation for allowing a waiver if
> approved by just “at least one” of the stakeholders,
> instead of all of them?
> 2. I’m a bit concerned that language might be
> increasingly troublesome as we continue to expand the
> scope and participation of this group.
>
> I believe it might be difficult to get approval from all
> stakeholders within a certain amount of time, meaning the
> CA would possibly never get all approvals, and never be
> able to utilize the waiver.
>
> Considering that signed code is often (but not
> exclusively) targeted for a specific platform,
> stakeholders of other platforms might not be inclined to
> give approval for something that does not even affect them.
>
> I do share your concern, but I also don’t see a better
> path towards the same goal.
>
> 3. Similarly, I’m unsure how I feel about making
> compliance distinctions based on whether a particular
> root program has decided to have a contractual
> relationship with its issuers or not. That seems like
> an implementation detail of the relationship that the
> guidelines should remain silent on. But I appreciate
> what that definition is intended to do, and would like
> to perhaps find a different way to express the same
> intent.
>
> Good point, and maybe the word “contract” is too much here?
>
> Although I would note this language is already part of the
> “Certificate Beneficiaries” definition right now.
>
> I’m open for a different suggestion
>
> *From:*Tim Hollebeek <tim.hollebeek at digicert.com>
> *Sent:* Friday, 15 July 2022 18:18
> *To:* Martijn Katerbarg <martijn.katerbarg at sectigo.com>;
> cscwg-public at cabforum.org
> *Subject:* RE: [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> 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.
>
> What is the motivation for allowing a waiver if approved
> by just “at least one” of the stakeholders, instead of all
> of them?
>
> I’m a bit concerned that language might be increasingly
> troublesome as we continue to expand the scope and
> participation of this group.
>
> Similarly, I’m unsure how I feel about making compliance
> distinctions based on whether a particular root program
> has decided to have a contractual relationship with its
> issuers or not. That seems like an implementation detail
> of the relationship that the guidelines should remain
> silent on. But I appreciate what that definition is
> intended to do, and would like to perhaps find a different
> way to express the same intent.
>
> -Tim
>
> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org>
> *On Behalf Of *Martijn Katerbarg via Cscwg-public
> *Sent:* Monday, June 27, 2022 10:04 AM
> *To:* cscwg-public at cabforum.org
> *Subject:* [Cscwg-public] Proposal to make changes to
> revocation based on malware
>
> All,
>
> As already hinted during the last meeting during the F2F,
> Ian and I, have been working on a proposal affecting the
> guidelines regarding malware based revocation.
>
> The intent of this change is to:
>
> 1. Limit the number of days before a certificate needs to
> be revoked, especially when the subscriber is not
> responding to inquiries
> 2. Remove the OCSP log analysis requirements
> 3. Simplify the process that has to be followed
>
> I have attached 3 documents: one with the current
> language, one with the proposed language, as well as a
> redlined version.
>
> The changes have been made based on upcoming version 3.0
> of the CSCBRs. In case you wish to compare with version
> 2.8, the relevant section is 13.1.5.3. Besides to that
> section, there is also a change to the “Suspect Code”
> definition, as well as a new definition in the proposal.
>
> Once PR6
> <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fcode-signing%2Fpull%2F6&data=05%7C01%7Cmartijn.katerbarg%40sectigo.com%7Cac3b5415ec5b408303cf08dadea00c1d%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638067076260946675%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=KWTNQAJF4EtXCjtfgtFDvLKfUcDMPQsc%2B%2FgzZSLrM90%3D&reserved=0>
> has been merged, I will also prepare the changes in GIT
> for those that prefer comparing there.
>
> Looking forward to comments to this and move towards a
> potential ballot.
>
> Regards,
>
> Martijn
>
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