[cabfpub] Concerns regarding Mozilla Root Program/Baseline Requirements

Fri Aug 2 13:45:41 UTC 2013

+1 

..and just to be clear, we are talking about a re-key where only the key
(and therefore SKI) change as well as the unique elements of serial number
and start date.   All other information remains the same as the previous
certificate.    This is what the majority of players in the CA industry
today deem "re-issuance" and it's mainly due to the complexity of PKI on
platforms coupled with the increase in virtualisation where keys seem to
be lost more frequently that has caused the CA industry to offer these
types of services to help PKI grow - without the need for customers to buy
separate insurance cover to help pay for this service or be charged a 2nd
time for accidental loss.   It's not something one CA can take away by
itself and it's not easily something one CA can change by itself, but it's
one area we all seemed to miss when looking at reduction of maximum
certificate duration from 60 to 39 so that should be the focus (As Rich
states and as I identified).

Steve

On 02/08/2013 14:30, "Rich Smith" <richard.smith at comodo.com> wrote:

>Jeremy,
>I agree with your reasoning, but at the same time, I don't think that we
>ever really thought in all the way through regarding the re-key/reissuance
>of certificates which had already been sold.  As I said in my recent reply
>to Sigbjorn, I'm not really all that concerned with certs sold for longer
>than 60 month term prior to the BRs.  If the consensus is that those need
>to
>have time cut off, I can live with that, but I would like to see us come
>up
>with a reasonable compromise to deal with those certs which are fully
>under
>the BR umbrella that fall into the 60 to 39 month change over period.
>-Rich
>
>> -----Original Message-----
>> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org]
>> On Behalf Of Jeremy Rowley
>> Sent: Friday, August 02, 2013 7:26 AM
>> To: 'Sigbjørn Vik'; public at cabforum.org
>> Subject: Re: [cabfpub] Concerns regarding Mozilla Root Program/Baseline
>> Requirements
>> 
>> As pointed out, a ten year or five year timeline for implementing
>> change in the industry is very long.  This was discussed extensively
>> during adoption of the BRs where we finally agreed to a five year
>> timeline that would shift to 3 years in 2015.  I'm strongly opposed to
>> going back and re-evaluating these timelines now, especially
>> considering the amount of discussion, debate, and compromise went into
>> it last time.
>> 
>> -----Original Message-----
>> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org]
>> On Behalf Of Sigbjørn Vik
>> Sent: Friday, August 02, 2013 4:56 AM
>> To: public at cabforum.org
>> Subject: Re: [cabfpub] Concerns regarding Mozilla Root Program/Baseline
>> Requirements
>> 
>> I think the BRs are clear on what they require, and the EV definitions
>> clearly spell out that renewals and reissuances create newly issued
>> certificates. All new certificates require valid validity periods.
>> While I can understand that people may want to discuss if the rules are
>> optimal, I dislike CAs claiming ignorance of the rules, or exception to
>> the rules since they have done things differently in the past. If
>> someone wants to claim the rules are unclear, do so before assuming a
>> particular interpretation, not afterwards.
>> 
>> Opera is happy to work with the group to define optimal rules, but we
>> dislike CAs engaging in creative reinterpretation of the rules. If we
>> can't trust that CAs follow the rules decided upon, then the rules are
>> close to worthless.
>> 
>> In addition to reasons mentioned previously about why constrained
>> validity periods is a good idea, there is also the point about the web
>> moving forwards. For us to be able to upgrade requirements, ditch
>> insecure practices, and promise a secure experience in the future, we
>> need to limit the time limit of certificates today. This is basic
>> insurance for the web in the future. Any exceptions we carve out today,
>> take away from this insurance, and might end up costing us a lot. This
>> is not a zero-sum game, and decisions we make today might have serious
>> consequences some years down the road.
>> 
>> This discussion has also highlighted some other issues:
>> * It seems some CAs are happy to issue backdated certificates. We
>> should probably spell out that signing, issuance and first validity
>> dates should all be as close as possible, with a maximum discrepancy
>> allowance.
>> * To be able to verify this, we should also require that any CT
>> registrations happen within that time limit. I will contact the CT team
>> and ask them to consider this.
>> * It seems audits don't catch CAs issuing certificates contrary to the
>> BR.
>> What can we do to ensure that audits catch such issues?
>> * Does the CABForum need an explicit objective?
>> 
>> On 01-Aug-13 15:08, Rich Smith wrote:
>> > Taking Ryan's definition and subsequent logic would effectively
>> > nullify all pre-BR agreements made with thousands of CA customers who
>> > bought certificates for terms greater than the now allowed 60 months
>> > max (and soon to be 39 month max).  My lay opinion is that such
>> action
>> > would open the CAs to lawsuits for breach of those agreements.
>> 
>> For CAs not to follow the BRs would presumably open them to lawsuits
>> from those who rely on the CAs for trust. For browsers not to follow
>> due diligence and best practices would presumably open them to lawsuits
>> from their customers. So if you care about potential lawsuits, the
>> score is
>> 2-1 for not issuing such certificates. However, I think potential
>> lawsuits are irrelevant. The goal of this group should be to secure the
>> web, not to ensure the short-term profits for individual members. (See
>> the last point above, about an objective.)
>> 
>> On 01-Aug-13 17:00, Steve Roylance wrote:
>> > [...] in 2015 when the
>> > industry flips to a 39 month max I believe from my engineering team
>> we
>> > would have had a similar issue to others, again due to the existing
>> > contract precedence understanding that others have mentioned.
>> 
>> That would be strange. Since the BRs were adopted in November 2011, all
>> CAs have known (and been audited on) the fact that after 1 April 2015
>> the maximum validity period is 39 months. For CAs today to sell
>> certificates valid more than 39 months past that date, and promise to
>> reissue them at any point would be shooting themselves in the foot.
>> 
>> --
>> Sigbjørn Vik
>> Opera Software
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