[cabfpub] 17.5 Audit of Delegated Functions

[Rick Andrews]

Right, I'm not talking about Enterprise CAs or RAs; external (to the CA) parties that the CA has granted the right to sign their own certificates (by way of the CA signing the  party's intermediate CA and including a name constraint in that intermediate). I think that meets the definition of Delegated Third Party. Is it the intent of the BRs not require them to be audited?

-Rick

From: Ben Wilson [mailto:ben at digicert.com]
Sent: Friday, December 21, 2012 10:53 AM
To: Rick Andrews; public at cabforum.org
Subject: RE: [cabfpub] 17.5 Audit of Delegated Functions

Rick,
Just so I understand your question more fully, you're talking about an external sub CA relying on name constraints and not an "Enterprise RA" or internal sub CA that is technically constrained in other ways?   When the BRs use the phrase "Delegated Third Party" (including in Section 11), that term means "a natural person or Legal Entity that is not the CA."
Ben

From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Rick Andrews
Sent: Friday, December 21, 2012 11:43 AM
To: public at cabforum.org
Subject: [cabfpub] 17.5 Audit of Delegated Functions

CABF members,
It's come to our attention that several people are interpreting this section of BR:
17.5 Audit of Delegated Functions
If a Delegated Third Party is not currently audited in accordance with Section 17 and is not an Enterprise RA, then
prior to certificate issuance the CA SHALL ensure that the domain control validation process required under Section
11.1 has been properly performed by the Delegated Third Party by either (1) using an out-of-band mechanism
involving at least one human who is acting either on behalf of the CA or on behalf of the Delegated Third Party to
confirm the authenticity of the certificate request or the information supporting the certificate request or (2)
performing the domain control validation process itself.
to mean that a Delegated Third Party that runs an External SubCA can avoid audit indefinitely if it simply has a name constraint in the SubCA limiting the domain names that it can issue to. The CA would be complying with "(2) performing the domain control validation itself" before it put the name constraint in the SubCA.
This seems like a loophole to us, because without an audit, there's no way to be sure that the Delegated Third Party is putting properly vetted info in the Subject DN field, and populating certs with the required extensions.
I doubt this was the intent, because I had the impression that most people thought External SubCAs were a risky practice that needed to be more tightly controlled. This seems to allow them to be less tightly controlled. Comments?
-Rick


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