[cabfpub] Concerns regarding Mozilla Root Program/Baseline Requirements

Steve Roylance steve.roylance at globalsign.com
Sat Aug 3 13:06:19 UTC 2013

Hi Wayne.

GlobalSign would endorse this language helping us all to move this forward

I would not like to slow approval by trying to add language about changes
to OIDs or Policy at this stage.    In some cases customers need to have
exactly the same certificate Subject DN so it's not possible to amend
(adding an OU statement etc).   Policy OID seems problematic too as cross
referencing to a specific CPS version would be quite confusing for relying
parties.    The only thing I can see that makes long term sense is having
a direct CPS reference, however, here again cycles between CPS updates
(Which may simply be to clarify wording rather than something that
materially affects the content of a certificate) and engineering updates
may be difficult to align, hence why I prefer to move forward with the
date based wording (as this is effectively what happens today) and not
rush a knee jerk reaction to other areas.


On 03/08/2013 00:03, "Wayne Thayer" <wthayer at godaddy.com> wrote:

>I took a stab at updating Rich's proposal based on what I perceive to be
>the consensus of what it means to rekey (not the definitions I've been
>Motion Begins 
>Add the following definitions to section 4:
>Reissue - the act of issuing a new Certificate with the identical Subject
>and Expiry Date as a previously issued and valid Certificate, to the same
>Subscriber as the original Certificate.
>Rekey - see Reissue.
>Add section 9.4.1 Reissuance
>Reissued Certificates MUST conform to all requirements set forth in this
>document for newly issued Certificates, including those in sections 9.4
>(Validity Period) and 11.3 (Age of Certificate Data).
>In spite of the requirements set forth in the preceding paragraph,
>Certificates issued prior to the effective date of this document having a
>Validity Period greater than 60 months, AND; Certificates issued prior to
>1 April 2015, having a Validity Period greater than 39 months; MAY be
>Reissued  with a Validity Period exceeding these requirements but not to
>exceed the Valid To date of the originally issued certificate, provided
>that the Reissued Certificate is otherwise in full compliance with all
>other technical and verification requirements contained in this document.
>Motion Ends
>-----Original Message-----
>From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On
>Behalf Of Ryan Sleevi
>Sent: Friday, August 02, 2013 2:56 PM
>To: kirk_hall at trendmicro.com
>Cc: public at cabforum.org
>Subject: Re: [cabfpub] Concerns regarding Mozilla Root Program/Baseline
>On Fri, Aug 2, 2013 at 2:28 PM, kirk_hall at trendmicro.com
><kirk_hall at trendmicro.com> wrote:
>> We also agree.  We were part of all BR discussions, and the effect of
>>rekeying was never discussed.  If it had been, our position would have
>>been that rekeying would not make a cert that was issued before the BRs
>>become subject to the BRs -- that would put CAs in the position of
>>having to breach their valid pre-BR contracts (which promised rekeying
>>if needed) with their customers -- something no CA would have agreed to,
>>barring a showing of an extraordinary security risk which we don't have
>> Disclosure:  we have no certificates affected by this discussion, but
>>think the Forum would do better to focus on actual, current risks that
>>need to be remedied, and let the improvements we have already made
>>through the BRs take effect as older certificates expire by their terms.
>I think the clearly fundamental disagreement on 'issuance' puts at risk
>every other advance we might make in the BRs to address the actual,
>current risks, which is why we raised this issue and are thankful to see
>the spirited discussion.
>It's been made abundantly clear that, during discussions on expirations,
>CAs were implicitly assuming that re-keying and re-issuance would be
>exempt from the BRs. However, I think that highlights the challenge - if
>that's a valid interpretation, there's absolutely nothing in the BRs to
>suggest it's "dates only" - after all, why not issue arbitrary
>extensions, unverified names, etc? Why not add new fields or extensions?
>After all, if the pre-BR contracts promised certain functionality that
>the BRs prohibit - whether it be expiration or any other aspect - why
>wouldn't this be acceptable?
>You can see that, at a minimum, we should least converge on an acceptable
>definition about what certificate fields can be manipulated, and what the
>CA is obligated to do when issuing new certificates under pre-BR
>While not exactly a "Yes" vote for Rich's proposal, I think it's
>certainly the most reasonable attempt to close this hole.
>I just hope and expect CAs are fully aware and considering the
>implications of the language - as it appears they may not have when
>negotiating the BRs - and how this might affect other provisions:
>domain validation, subject information, EKUs, revocation responders,
>serial numbers/entropy, etc. It's entirely possible that such 'reissued'
>certificates will differ much more significantly than just flipping some
>dates and/or a key.
>> -----Original Message-----
>> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org]
>> On Behalf Of Steve Roylance
>> Sent: Friday, August 02, 2013 6:46 AM
>> To: Rich Smith; jeremy.rowley at digicert.com; 'Sigbjørn Vik';
>> public at cabforum.org
>> Subject: Re: [cabfpub] Concerns regarding Mozilla Root
>> Program/Baseline Requirements
>> +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
>> 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:
>>>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.
>>>> -----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
>>>> 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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