[cabfpub] Ballot 173 - Removal of requirement to cease use of private key due to incorrect certificate info

Fri Jul 22 09:53:19 MST 2016

For an industry based on trust, 6 months to make changes seems an
exceptionally long time, and you haven't really provided a justification
for why that date over, say, 18 months, 3 months, or 3 days.

I totally understand and appreciate changes take time, but I still believe
we need to take it on a case-by-case basis and default to sooner, with a
willingness to discuss what's commercially reasonable or viable if some
reason prevents it being made sooner.

For example, consider the practical implications of this - any CA that
allows a subscriber to add and remove SANs from certs, whether as part of a
managed PKI or as part of a product offering, is potentially in breach of
this obligation if they don't force a mandatory rekey (and I suspect many
don't, precisely because of the consumer hassle).

That is, if you have a cert for "a.example.com" and "b.example.com", and
you remove "b.example.com" from the cert, then according to this, the
subscriber needs to request revocation (the information is "incorrect" or
"inaccurate"), and needs to change keys.

Surely that's the kind of situation we'd rather fix sooner than later,
right? So if we said 45 days - or even went for an even 60 - does that meet
your needs?

On Fri, Jul 22, 2016 at 9:26 AM, Rich Smith <richard.smith at comodo.com>
wrote:

> I've said in the past that I believe any non-critical change should have a
> 6 month lead time by default.  I stand by that statement and submit it
> again.  And yes, Ryan, that goes whether the change toughens or relaxes the
> requirements.  CAs are of course free and encouraged to bring themselves
> into compliance sooner if they are able to do so without turning their
> existing dev cycle on it's head, but I don't think 6 months is unreasonable
> for a non-critical change either way.
>
> -Rich
>
>
> On 7/21/2016 11:02 PM, Ryan Sleevi wrote:
>
> Dean,
>
> In the past, when CAs have had concerns, there's been a suggestion of a
> timeframe that might be reasonable to make changes.
>
> Is thirty days sufficient? Why or why not?
>
> When the proposed changes relax, rather than toughen, a requirement, do
> you share the same concerns?
>
> On Jul 21, 2016 7:32 PM, "Dean Coclin" <Dean_Coclin at symantec.com> wrote:
>
>> Josh,
>>
>> This is not a criticism of this specific ballot; I have no comment on its
>> merit. However, in reviewing several recent ballots, I think it's
>> problematic to have a ballot state that it is effective as of the date of
>> passage.
>>
>> If a CA has to make technical or policy changes, it's going to take some
>> time to do so. If the ballot takes effect on the day of passage, then the
>> CA has to make immediate changes, lest they be technically out of
>> compliance as of that day.
>>
>> For example, this ballot will require CAs to make CPS changes. How are
>> they supposed to do this in one day? Am I reading this correctly?
>>
>> Thanks,
>> Dean
>>
>>
>>
>> -----Original Message-----
>> From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org]
>> On Behalf Of Josh Aas
>> Sent: Thursday, July 14, 2016 10:18 AM
>> To: CABFPub <public at cabforum.org>
>> Subject: [cabfpub] Ballot 173 - Removal of requirement to cease use of
>> private key due to incorrect certificate info
>>
>> Ballot 173 - Removal of requirement to cease use of private key due to
>> incorrect certificate info
>>
>> The following motion has been proposed by Josh Aas of ISRG / Let's
>> Encrypt. Ben Wilson of Digicert and Chris Bailey of Entrust endorse.
>>
>> Background:
>>
>> BR Section 9.6.3 point 5 says:
>>
>> "Reporting and Revocation: An obligation and warranty to promptly cease
>> using a Certificate and its associated Private Key, and promptly request
>> the CA to revoke the Certificate, in the event that: (a) any information in
>> the Certificate is, or becomes, incorrect or inaccurate, or (b) there is
>> any actual or suspected misuse or compromise of the Subscriber’s Private
>> Key associated with the Public Key included in the Certificate;"
>>
>> There is a problem here, which is that this requires a subscriber to stop
>> using a private key just because information in a certificate is inaccurate
>> or incorrect. People should stop using a cert with inaccurate or incorrect
>> information, but they shouldn't be required to stop using a key pair unless
>> there is known or suspected compromise.
>>
>> This is particularly problematic for HPKP.
>>
>> --Motion Begins--
>>
>> Effective upon the date of passage, the following modifications are made
>> to the Baseline Requirements:
>>
>> Change the following text in Section 9.6.3:
>> =======================
>> Reporting and Revocation: An obligation and warranty to promptly cease
>> using a Certificate and its associated Private Key, and promptly request
>> the CA to revoke the Certificate, in the event that: (a) any information in
>> the Certificate is, or becomes, incorrect or inaccurate, or (b) there is
>> any actual or suspected misuse or compromise of the Subscriber’s Private
>> Key associated with the Public Key included in the Certificate;
>> =======================
>>
>> To:
>> =======================
>> Reporting and Revocation: An obligation and warranty to: (a) promptly
>> request revocation of the Certificate, and cease using it and its
>> associated Private Key, if there is any actual or suspected misuse or
>> compromise of the Subscriber’s Private Key associated with the Public Key
>> included in the Certificate; and (b) promptly request revocation of the
>> Certificate, and cease using it, if any information in the Certificate is
>> or becomes incorrect or inaccurate.
>> =======================
>>
>> --Motion Ends--
>>
>> The review period for this ballot shall commence at 2200 UTC on 14 July
>> 2016, and will close at 2200 UTC on 21 July 2016. Unless the motion is
>> withdrawn during the review period, the voting period will start
>> immediately thereafter and will close at 2200 UTC on 28 July 2016. Votes
>> must be cast by posting an on-list reply to this thread.
>>
>> A vote in favor of the motion must indicate a clear 'yes' in the
>> response. A vote against must indicate a clear 'no' in the response. A vote
>> to abstain must indicate a clear 'abstain' in the response.
>> Unclear responses will not be counted. The latest vote received from any
>> representative of a voting member before the close of the voting period
>> will be counted. Voting members are listed here:
>> https://cabforum.org/members/
>>
>> In order for the motion to be adopted, two thirds or more of the votes
>> cast by members in the CA category and greater than 50% of the votes cast
>> by members in the browser category must be in favor. Quorum is currently
>> ten (10) members– at least ten members must participate in the ballot,
>> either by voting in favor, voting against, or abstaining.
>>
>> --
>> Josh Aas
>> Executive Director
>> Internet Security Research Group
>> Let's Encrypt: A Free, Automated, and Open CA
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