[cabfpub] Increasing concurrent compliance compatibility

[Ryan Sleevi]

On Thu, Jul 21, 2016 at 2:24 PM, Peter Bowen <pzb at amzn.com> wrote:

> I propose that we amend the BRs to change the “trigger” for OV/IV to be
> the explicit inclusion of the appropriate CA/B Forum policy identifier
> rather than an implicit trigger based on attributes found in the Subject
> distinguished name.
>
> This would allow CAs who are issuing certificates that need to comply with
> both the BRs and other certificate policies the ability to set the subject
> distinguished name as needed.  For example, some CAs may need to follow
> X.521 for the DN while others may need to use the country, state/province,
> and locality attributes to indicate legal jurisdiction rather than physical
> address and others may need to ensure that each legal or natural person has
> a distinct DN.
>
> Concretely, if a certificate has one or both of:
> {joint‐iso‐itu‐t(2) international‐organizations(23) ca‐browser‐forum(140)
> certificate‐policies(1) baseline‐ requirements(2)
> organization‐validated(2)} (2.23.140.1.2.2)
> {joint‐iso‐itu‐t(2) international‐organizations(23) ca‐browser‐forum(140)
> certificate‐policies(1) baseline‐ requirements(2) individual‐validated(3)}
> (2.23.140.1.2.3)
> in its certificate policies extension, then the current BR requirements
> apply to the subject DN.
>
> If neither are in the certificate policies extension, then the only
> Subject DN restriction would be on the commonName (CN) attribute.  All
> other attributes would be set according to the non-CABF policy for the
> certificate
>
> I believe this would help resolve the issues Li-Chen has raised and I
> think it would help existing PKIs, such as the US Federal PKI, align their
> policies with the CABF BRs.
>
> Anyone agree or disagree?
>
> Thanks,
> Peter
>

Doesn't this create a rather large loophole for potential abuse/mistakes?

For example, I'm not aware of any browser that specifically recognizes the
OV OID, but all display the organization information in some way, most
commonly as some short-name in some form of UI. As proposed, if a CA didn't
assert the OV OID, then it would seem reasonable that a CA might decide
that no policies apply, and put "Google, Inc" in the O field.

Is that desirable? Is that right?

It's unclear whether CAs reasonably understand 7.1.2.4 (b), or whether that
clearly prohibits that - or if it even should.

Similarly, what happens to 7.1.4.2.2 (i)? Do you see that being exempt?

Given Relying Party applications' longstanding and preexisting use of the
fields (in particular, those noted in 7.1.4.2.2 a-h), I'm concerned with
the introduction of semantics that would, in effect, change the meaning
based on the policies asserted. If we were starting over from scratch, I
would think it'd be an entirely reasonable suggestion, but given the
preponderance of legacy systems in place, it seems slightly troublesome on
principle to allow 'caveat CA' to rule here.
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