[cabfpub] EV Guidelines §14.2 delegation of functions to RAs etc.

Peter Bowen pzb at amzn.com
Mon Aug 29 07:14:56 MST 2016


Adriano,

My understanding is that there are two classes of RAs:

- Enterprise RAs
- Unconstrained RAs

Unconstrained RAs can independently obtain and review evidence to determine who controls or owns a domain.  The CA may, when receiving an authenticated issuance request from an Unconstrained RA, issue the certificate with no further checks.  In order to help assure that the Unconstrained RA is following the requirements of the CA, to include the CA/Browser Forum requirements, the Unconstrained RA must undergo an audit very similar to that which the CA undergoes.

Enterprise RAs were defined because the burden of audit was seen as too great for most cases.  An Enterprise RA has a defined scope and is responsible for the validation of authority within that scope.  The CA (or Unconstrained RA) is responsible for validating that the Enterprise RA operator is authorized to be the authority for the namespace(s) covering certificates the Enterprise RA authorizes.  The EV Guidelines ensure that the CA is liable this action by requiring the CA to issue an EV certificate containing the Enterprise RA operator information.  This ensures that the full Extended Validation process has been followed.

Once the Enterprise RA’s scope has been validated, they can issue for anything within that scope, including the scope itself.  For example, if I operate an Enterprise RA with a validated EV scope of “webpki.com”, I can validate an EV certificate request for “webpki.com”, “shop.webpki.com”, “router.lhr.webpki.com”, or “www.webpki.com”.  However I cannot do initial validation for “sslmap.com” even though I own that domain as well; instead someone with an audited process must add it to my validated EV scope list at which point I can validate an EV certificate request for “sslmap.com” or “gateway.lax.sslmap.com”.

As I pointed out before, there is nothing that says the EV certificate(s) defining the validation scope must be publicly used or even be usable by common clients.  It would be completely valid to put a “poison” extension that renders it unusable with clients and ensures that the only purpose is to assert the scope.  I think a very sane implementation of Enterprise RA might choose this method, then have the Enterprise RA use this certificate and associated private key to sign issuance requests it has validated.

Given that Enterprise RAs are unaudited entities which have no defined oversight, why should they have the authority to issue for any name without further checks?

Thanks,
Peter


> On Aug 29, 2016, at 1:31 AM, Adriano Santoni <adriano.santoni at staff.aruba.it> wrote:
> 
> 3) At any rate, even under the conditions above, once a subject organization has been enabled as an Enterprise RA for EV cert, they can only obtain EV certs for sub-domains of the SLDN contained in their first EV certificate. 
> 
> Why so? Why cannot the Enterprise RA, at this point, obtain further EV certs for just any domain (esp. SLDN) they own or control? But if this is actually allowed, than it's certainly not clear in the EVGLs.
> 
> Adriano
> 
> 
> Il 24/08/2016 18:59, Ryan Sleevi ha scritto:
>> Adriano,
>> 
>> It might be useful if you could explain more why you believe the text disagrees with Kirk, Peter and I. The goal is not to leave these things up to interpretation, and so if you believe a plain reading of the text supports an alternative understanding different from what we said, understanding why you believe that will be quite important.
>> 
>> On Wed, Aug 24, 2016 at 2:44 AM, Adriano Santoni <adriano.santoni at staff.aruba.it> wrote:
>> Kirk,
>> 
>> thank you for your contribute. 
>> 
>> If the "correct interpretation" of the EVGL is actually the one you give below, than it makes sense. 
>> 
>> But I see that even you are expressing some uncertainty ("looks like"... "in my opinion" ...) so I really would like to understand whether your interpretation is shared by most CA members, as I hope. 
>> 
>> If your interpretation is correct, I think that the EVGLs are worth improving, for better clarity.
>> 
>> On the other hand, the notion that an Enterprise RA can only authorize issuance of EV certs for sub-domains seems weird to me. 
>> I wonder how many EV certificates exist for subdomains of a company's main domain.... I suppose not many?
>> 
>> Adriano
>> 
>> 
>> 
>> Il 17/08/2016 18:56, Kirk Hall ha scritto:
>>> Adriano, I may not be understanding your original question -- but here is another possible answer.
>>> 
>>>  
>>> If Company A applies for an EV cert for foo.com, the CA will do an EV vetting for the organization (Company A) and then for the domain (foo.com).  Under EVGL 14.2, it looks like Company A can then ask to be designated as an Enterprise RA - but only for the confirmed domain foo.com -- and then get certs for third level and higher domains that end in foo.com.  But Company A has not proven ownership or control of any other domains, such as bar.com, so is not an Enterprise RA for any other domains.
>>> 
>>>  
>>> Now suppose Company A comes back to the RA and asks for a cert for bar.com.  In my opinion, the CA is not required to re-do EV organization validation for Company A again -- it can rely on the earlier EV organization validation (for the full 13 month period), so long as the CA is certain it is really dealing with Company A.  But it must do EV validation of bar.com to prove it is owned or controlled by Company A.  Once that has been done, Company A could ask to be designated as an Enterprise RA for bar.com also.  But there is no real connection between the status of foo.com versus bar.com, other than Company A may only have to go through a single EV organization vetting.
>>> 
>>>  
>>> Is that responsive to your original question?
>>> 
>>>  
>>> -----Original Message-----
>>> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On Behalf Of Peter Bowen
>>> Sent: Friday, August 5, 2016 9:19 AM
>>> To: Adriano Santoni <adriano.santoni at staff.aruba.it>
>>> Cc: CABFPub <public at cabforum.org>
>>> Subject: Re: [cabfpub] EV Guidelines §14.2 delegation of functions to RAs etc.
>>> 
>>>  
>>> I don’t think this is a very high bar.  It would seem the following process would work:
>>> 
>>>  
>>> 1) Customer requests EV Enterprise RA privileges for example.com, example.net, corp.example.org, example.biz, …
>>> 
>>>  
>>> 2) CA follows EV issuance procedures and issues a single EV certificate that has all the base domains in it.  This certificate could have a CA-defined critical extension marking it an “Enterprise RA EV” certificate or some such to prevent it from being used on a server.  I think it could even have CA-generated key pair where the CA simply threw away the private key after generation. 
>>> 
>>>  
>>> 3) If the customer wants new domains, the CA issues a new “Enterprise RA EV” certificate using the same process.  There does not appear to be a requirement that all domains be in a single certificate, so it could just be the new domains.
>>> 
>>>  
>>> I think this would meet all the requirements that are set out.
>>> 
>>>  
>>> Thanks,
>>> 
>>> Peter
>>> 
>>>  
>>> > On Aug 4, 2016, at 11:58 PM, Adriano Santoni <adriano.santoni at staff.aruba.it> wrote:
>>> 
>>> >
>>> 
>>> > Ok,. but what is (was) the ratio for that constraint?
>>> 
>>> >
>>> 
>>> > Assume the following:
>>> 
>>> >
>>> 
>>> > 1) A certain company (say "ACME Corp") owns/controls several 2nd level domains (two or more).
>>> 
>>> >
>>> 
>>> > 2) That company wants EV certificates, from a certain CA, for two or more of those domains, or possibly all of them.
>>> 
>>> >
>>> 
>>> > 3) The same company would like to be authorized as an Enterprise RA by the said CA.
>>> 
>>> >
>>> 
>>> > Now assume that the said CA, first of all, verifies (with _positive result_) that *all* of those domains are actually owned/controlled by ACME.
>>> 
>>> >
>>> 
>>> > Next, the CA verifies that all requirements for issuing the first EV certificate (for any one of those domains) are met, and therefore issues the first EV certificate.
>>> 
>>> >
>>> 
>>> > At this point, why should ACME not be allowed to act as an Enterprise RA and thus obtain by themselves (in compliance with all applicable reqs. for Enterprise RAs) the desired EV certificates for the remaining 2nd level domains ?
>>> 
>>> >
>>> 
>>> > What would be the implied risk of allowing that?
>>> 
>>> > Adriano
>>> 
>>> >
>>> 
>>> >
>>> 
>>> >
>>> 
>>> > Il 04/08/2016 23:24, Ryan Sleevi ha scritto:
>>> 
>>> >> You're saying the original certificate is xxx.example, and the new certificate is for xxx.example and yyy.example?
>>> 
>>> >>
>>> 
>>> >> No, it would not be appropriate, because yyy.example was not "contained within the domain of the original EV certificate"
>>> 
>>> >>
>>> 
>>> >> On Thu, Aug 4, 2016 at 6:19 AM, Adriano Santoni <adriano.santoni at staff.aruba.it> wrote:
>>> 
>>> >> All,
>>> 
>>> >>
>>> 
>>> >> I have a doubt regarding §14.2 of EV guidelines, and particularly §14.2.2 (Enterprise RAs) that reads:
>>> 
>>> >>
>>> 
>>> >> "The CA MAY contractually authorize the Subject of a specified Valid EV Certificate to perform the RA function and authorize the CA to issue additional EV Certificates at third and higher domain levels that are contained within the domain of the original EV Certificate (also known as an Enterprise EV Certificate). In such case, the Subject SHALL be considered an Enterprise RA, and the following requirements SHALL apply: ..."
>>> 
>>> >> Now, let's assume that a certain company owns/controls two or more domains, say xxx.com and yyy.net, and that the "original EV Certificate" (quoted from above) was issued by the CA for any one of those domains (say xxx.com): under these conditions, would it be okay to authorize that company to act as an Enterprise RA for the remaining 2nd-level domains that it owns/controls ?
>>> 
>>> >>
>>> 
>>> >> Based on §14.2.2, it seems not.
>>> 
>>> >>
>>> 
>>> >> Adriano
>>> 
>>> >>
>>> 
>>> >>
>>> 
>>> >> _______________________________________________
>>> 
>>> >> Public mailing list
>>> 
>>> >> Public at cabforum.org
>>> 
>>> >> https://cabforum.org/mailman/listinfo/public
>>> 
>>> >>
>>> 
>>> >>
>>> 
>>> >
>>> 
>>> > --
>>> 
>>> > Cordiali saluti,
>>> 
>>> >
>>> 
>>> > Adriano Santoni
>>> 
>>> > ACTALIS S.p.A.
>>> 
>>> > (Aruba Group)
>>> 
>>> >
>>> 
>>> > _______________________________________________
>>> 
>>> > Public mailing list
>>> 
>>> > Public at cabforum.org
>>> 
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>>> 
>>>  
>>> _______________________________________________
>>> 
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>> 
>> -- 
>> Cordiali saluti,
>> 
>> Adriano Santoni
>> ACTALIS S.p.A.
>> (Aruba Group)
>> 
>> 
>> _______________________________________________
>> Public mailing list
>> Public at cabforum.org
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>> 
>> 
> 
> -- 
> Cordiali saluti,
> 
> Adriano Santoni
> ACTALIS S.p.A.
> (Aruba Group)
> 
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