[cabfpub] Pre-Ballot 164 - Certificate Serial Number Entropy

[Ryan Sleevi]

On Thu, Apr 28, 2016 at 1:15 PM, Rich Smith <richard.smith at comodo.com>
wrote:

> I do think this brings up a good point though.  This has come up before
> under other ballots requiring code changes to CA core systems.  I think
> that any change requiring such code changes should have a minimum lead time
> of 6 months from passage of the ballot before becoming mandatory, unless it
> is deemed to be a security threat sufficient to require more immediate
> action.  Admittedly I do not have the technical expertise to know if this
> is such a case.
>

Could you explain how you chose six months, as opposed to one month (the
time for legal review for Final Guidelines) or, say, three months?

Our experience with responding to security threats, at Google, in Chrome,
and in conjunction with other vendors (such as through efforts like Project
Zero), is that, in the worst case, the ability to respond to a security
threat in a timely manner is directly related to the ability to release and
deploy new versions and products of code. That is, even if we were to say
that an incident is security related, and thus perhaps requires 14 days to
effect change, there will be some portion of CAs who, through the structure
of business operations and third party engagements, will have difficulty
responding to anything outside of their contracted timeframe - such as the
six months you propose. By setting the expectation lower, such that it's
clear what the 'worst case' scenario may be, the overall security of the
ecosystem improves.

That said, I would also argue it's difficult to quantify what represents a
change to CA core systems, because that varies largely depending upon how
the CA has structured their operations. Because that's such a subjective
measure, and one for which there is an unfortunate long-tail of CAs who are
unable to take any necessary precautions in a timely fashion, setting that
as the bar may be disproportionately disadvantageous to security.
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