[cabfpub] Proposed motion to modify EV domain verification section

Tue May 7 07:56:39 MST 2013

This thread brings up an important syntactical improvement that we need to make in the BRs and EV Guidelines.  We ought to start now with EV, since that is what we’re currently discussing.  Occasionally people will say we need to be more exact with terms like “domain name”, “FQDN”, etc.  While we have made great improvements since EV 1.0, there are still more to be made.  

Let’s say that the FQDN or sub-domain is controlled under a license granted by the domain name registrant, but the domain name registrant might be difficult to contact, etc.   It might be clear from the domain name registrant’s architecture/business model that the registrant’s usual practice is to assign subdomains or set up FQDNs.  Similarly, it might be clear from the EV applicant’s usual practice that they obtain an assignment of a particular subdomain or particular FQDN as a service provider to domain name registrants.  I can see a practical demonstration through DNSSEC routing to particular IP address blocks shows sufficient control.  By issuing the EV certificate, I do not think we are attesting to domain name registration.  In most cases, yes, but in some we are attesting to the entity behind the server, FQDN or sub-domain, in which cases the process for validation changes because the goal has changed.    

Even if you do not accept these two hypotheticals, we still need to go through both documents with a fine-toothed comb to remove potential ambiguities.

From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Ryan Hurst
Sent: Monday, May 06, 2013 10:56 PM
To: jeremy.rowley at digicert.com; 'Eddy Nigg (StartCom Ltd.)'; public at cabforum.org
Subject: Re: [cabfpub] Proposed motion to modify EV domain verification section

While I agree the syntactic checks prescribed in Report 58 will increase the accuracy of information in WHOIS, the fact is it is supposed to be accurate today even though we know registrars do a bad job at meeting the requirement and ICANN does a bad job at mandating they meet it.

When it comes to the policies we author, I think we should build them on what is required by the entities involved and build mitigations for the reality of their practices; in this case it means WHOIS data should be allowed but be syntactically validated and corroborated with other data sources.

As for allowing other forms of domain control verification, I am not opposed to supporting mechanism that actually allow verification of control of the domain but some technical verifications in use today do not do that, for example they may verify control of a host within the domain which is different than controlling the domain itself.

Even if we do that though I think it’s important we still allow for WHOIS based verification, just as I think it’s important the registrars and ICANN live up to their obligations to ensure it is accurate.

Ryan

From: Jeremy Rowley [mailto:jeremy.rowley at digicert.com] 
Sent: Monday, May 06, 2013 9:40 PM
To: 'Ryan Hurst'; 'Eddy Nigg (StartCom Ltd.)'; public at cabforum.org
Subject: RE: [cabfpub] Proposed motion to modify EV domain verification section

I recognize that there is a self-reporting requirement and that SSAC Report #58 released this year has some recommendations that, if adopted, will greatly improve the WHOIS contents.  Considering the large number of WHOIS listings that are incorrect and that self-reported data is not permitted under EV, I think other verification requirements are more effective at determining the controller/owner of the website.

I think looking at what registrars do is a good way to expand the domain validation scope. However, I think the Forum already has several effective methods of verifying domain names in the BRs, and I do not see the harm in permitting these same procedures for EV.

Jeremy

From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Ryan Hurst
Sent: Monday, May 06, 2013 10:23 PM
To: jeremy.rowley at digicert.com; 'Eddy Nigg (StartCom Ltd.)'; public at cabforum.org
Subject: Re: [cabfpub] Proposed motion to modify EV domain verification section

Since 2003 ICANN has required the information to be validated yearly - http://www.icann.org/en/resources/registrars/consensus-policies/wdrp the policy was poorly written, did not consider global privacy requirements and is not enforced but it is at least mandated; http://www.circleid.com/posts/20120719_a_confession_about_icann_whois_data_reminder_policy/ 

I understand one of the key reasons of non-enforcement is that ICANN feels they do not have the teeth to do so in the existing contracts with registrars.

I also understand that they have addressed this contractual teeth issue with the gTLD contracts.

As we look at this topic I believe it is best to consider both what registrars are required to do and build mitigations based on what they truly do.

Ryan

From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Jeremy Rowley
Sent: Monday, May 06, 2013 9:00 PM
To: 'Eddy Nigg (StartCom Ltd.)'; public at cabforum.org
Subject: Re: [cabfpub] Proposed motion to modify EV domain verification section

We do require a human interaction (and that won’t change) when we verify the certificate requester.  However, that is separate from domain verification.  Considering that WHOIS information is essentially non-verified information, I don’t think the WHOIS check provides any insight about the domain’s operator.  Until ICANN requires verification of each domain applicant, the WHOIS information is less reliable (IMO) than several of the verification methods permitted under the baseline requirements.

From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Eddy Nigg (StartCom Ltd.)
Sent: Monday, May 06, 2013 9:56 AM
To: public at cabforum.org
Subject: Re: [cabfpub] Proposed motion to modify EV domain verification section

On 05/06/2013 05:42 PM, From Rich Smith: 

What's more, the EV requirement around domain verification is currently LESS
SECURE than OV/DV in this regard as it ONLY requires looking at WHOIS.  To
the best of my knowledge there has never been a case of any mis-issuance of
a certificate to an unauthorized domain where a technical mechanism was used
to verify domain authorization.

If anything we should probably require a technical verification and a human interaction via WHOIS to really improve it.

I'm not sure... if we'd simply rely on technical verification under certain circumstances certificates could be issued unintentional and then in the EV level. I'm not very comfortable with the thought to solemnly rely on a domain control validation. 

Also EV certificates should probably identify the entity that stands behind the web site (even though the guidelines allow for authorization and delegation of sites to a validated entity), it requires either a lookup at the WHOIS records and/or web sites involved to confirm that.

It is also extremely frustrating for a customer who, for example, gets a
request from us to unmask whois, gets an email sent to a WHOIS contact and
responds to it, then gets another request that they now have go back in and
change the WHOIS info because we have found it to not match now that we can
see it.  From their point of view, the email established that they own the
domain so we are now just wasting their time.

Yes, probably most of us are aware of the difficulties with that, on the other hand it also relays to the parties involved that an EV isn't that easy to get. Agreed that your proposal would reduce some of the hassle with that and make EV more convenient.

Regards 

Signer: 

Eddy Nigg, COO/CTO

StartCom Ltd. <http://www.startcom.org> 

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startcom at startcom.org

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