[cabfpub] [EXTERNAL] Forbid DTPs from doing Domain/IP Ownership Validation ballot draft

Wed Apr 26 22:05:12 UTC 2017

Gerv, I’m late to the discussion on this.  By can you start at the beginning, and explain why you believe DTPs should not be permitted to perform domain validation under any circumstances?

As a refresher, here is the definition of a DTP in the BRs: “Delegated Third Party: A natural person or Legal Entity that is not the CA but is authorized by the CA to assist in the Certificate Management Process by performing or fulfilling one or more of the CA requirements found herein.”

I’m not speaking from an Entrust use case, but I can imagine there could be cases where the CA has no one on staff who can read or interpret certain languages and alphabets (Russian Cyrillic, Greek, Arabic, Chinese, Japanese).  They want to do a WhoIs lookup, but can’t read or interpret what they see.  This could be a perfect situation for using a DTP for domain verification.

Clearly the work of all DTPs should be audited, and the DTP part of the audit should roll up somehow into the issuing CA’s audit.  I know that can be complex (and under current rules, may be hard for browsers to monitor and feel confident they understand the ENTIRE network of DTPs, etc. used by the CA under each root).  But it can be done.

I’m not personally familiar with the current complexity of making sure all DTPs are covered by a CA’s audit.  But wouldn’t it make sense to spend time working on the audit completeness problem (which is important in any case) and not forbid use of DTPs for domain verification?

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Gervase Markham via Public
Sent: Tuesday, March 28, 2017 6:55 AM
To: CABFPub <public at cabforum.org>
Cc: Gervase Markham <gerv at mozilla.org>
Subject: [EXTERNAL][cabfpub] Forbid DTPs from doing Domain/IP Ownership Validation ballot draft

Hi everyone,

Here's a draft of a ballot to forbid DTPs from doing Domain Validation, as discussed at the F2F. Again, this is early text, so comments on both the approach and the wording are very welcome.

Is an Enterprise RA a subset of Delegated Third Party, or a different thing? The BRs seem a little unclear on this. I think they are a separate thing, but there are some bits of wording this ballot modifies or removes that suggest that they are a subset. Comments?

Gerv

Ballot XXX - Forbid DTPs from doing Domain/IP Ownership Validation
Purpose of Ballot: At the moment, CAs are permitted to delegate the process of domain and IP address validation. However, permitting such delegations is problematic due to the way audits work - the auditing of such work may or may not be required and, if it is, those audit documents may not make it back to root programs for consideration. Although the audit situation also needs fixing, domain validation is an important enough component of a CA's core competencies that it seems wiser to remove it from the larger problem and forbid its delegation. The purpose of this ballot is to ensure that CAs or their Affiliates are always the ones performing domain/IP address ownership validation for certificates that CA is responsible for.
The following motion has been proposed by Gervase Markham of Mozilla and endorsed by XXX of XXX and XXX of XXX:

-- MOTION BEGINS --

1) In section 1.3.2 of the Baseline Requirements, replace the following sentence:

"The CA MAY delegate the performance of all, or any part, of Section 3.2 requirements to a Delegated Third Party, provided that the process as a whole fulfills all of the requirements of Section 3.2."

with:

"With the exception of sections 3.2.2.4 and 3.2.2.5, the CA MAY delegate the performance of all, or any part, of Section 3.2 requirements to a Delegated Third Party, provided that the process as a whole fulfills all of the requirements of Section 3.2."

2) In sections 3.2.2.4 and 3.2.2.4.11 (if still present in the text at the time the ballot passes), replace the following text:

"either the CA or a Delegated Third Party"

with:

"the CA"

3) In section 3.2.2.4.6, remove the words "or Delegated Third Party".

4) In section 8.4, remove the paragraph beginning: "If a Delegated Third Party is not currently audited...".

5) In section 8.4, replace the following text:

"If the CA is not using one of the above procedures and the Delegated Third Party is not an Enterprise RA, then"

with:

"For Delegated Third Parties (but not Enterprise RAs)".

-- MOTION ENDS --

The procedure for approval of this Final Maintenance Guideline ballot is as follows (exact start and end times may be adjusted to comply with applicable Bylaws and IPR Agreement):

BALLOT XXX

Status: Final Maintenance Guideline

Start time (23:00 UTC)

End time (23:00 UTC)

Discussion (7 to 14 days)

XXX

XXX

Vote for approval (7 days)

XXX

XXX

If vote approves ballot: Review Period (Chair to send Review Notice) (30 days).

If Exclusion Notice(s) filed, ballot approval is rescinded and PAG to be created.

If no Exclusion Notices filed, ballot becomes effective at end of Review Period.

Upon filing of Review Notice by Chair

30 days after filing of Review Notice by Chair

From Bylaw 2.3: If the Draft Guideline Ballot is proposing a Final Maintenance Guideline, such ballot will include a redline or comparison showing the set of changes from the Final Guideline section(s) intended to become a Final Maintenance Guideline, and need not include a copy of the full set of guidelines.  Such redline or comparison shall be made against the Final Guideline section(s) as they exist at the time a ballot is proposed, and need not take into consideration other ballots that may be proposed subsequently, except as provided in Bylaw Section 2.3(j).

Votes must be cast by posting an on-list reply to this thread on the Public list.  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 shown on CA/Browser Forum wiki.  Under Bylaw 2.2(g), at least the required quorum number must participate in the ballot for the ballot to be valid, either by voting in favor, voting against, or abstaining.
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