[cabfpub] Ballot 185 (Revised) - Limiting the Lifetime of Certificates

Mon Feb 20 11:19:53 UTC 2017

HARICA participated in the discussion of ballot 185. Our concerns can be 
summarized in the following:

  * This proposal will raise the administrative overhead of Subscribers
    significantly (from where it is today). System administrators time
    is considered "expensive" thus, this proposal raises the cost for
    Subscribers. We support automation tools for web sites but there are
    more things to consider:
      o SSL/TLS certificates are used for more than web services (FTPs,
        LDAPs, IMAPs, POP3s, Radius, SMTP, etc). Subscribers operating
        such services don't currently have the necessary tools to
        automate the renewal process every year and it is not
        anticipated that such tools will exist anytime soon (even in the
        year to come).
      o Some SSL/TLS certificates are used in Federated Services which
        require out-of-bad distribution (a very manual process).
      o There are many legacy devices that don't support automation in
        certificate management (Wireless Access Points, VPN servers, etc).
  * The CA/B Forum supports and requires ONLY _secure_ (to the best of
    the community's knowledge) cryptographic algorithms in the Baseline
    Requirements. These algorithms have a lifetime expectancy for
    sustaining attacks and factoring, of several years. In cases where
    an algorithm was proven or was even considered as insecure,
    appropriate deprecation measures were adopted, consistent with the
    vulnerabilities and threats. Of course there are lessons to be
    learned, and this process must be improved, even standardized.
    Requiring certificates to be issued every year does not substitute
    the necessity for appropriate deprecation measures.
  * We consider Google's S/MIME policy
    <https://support.google.com/a/answer/7300887> for certificate
    validity of 27 months, as the best next-step forward that should be
    adopted by the CA/B Forum for the Baseline Requirements. It will
    still raise the administrative overhead for Subscribers but it will
    be less aggressive and easier to adopt.

For the reasons above, HARICA votes "no" for ballot 185.

We would support creating an agreed-upon questionnaire by the Forum 
members (the same questionnaire for everyone) that will address most or 
all of the concerns raised in the discussion period of ballot 185. This 
questionnaire would be forwarded to CA Subscribers thus acquiring 
consistent, concrete data that will help the Forum decide future steps 
regarding the certificate validity period and domain validation (or 
re-validation). We may come back to this in a different thread, after 
the end of the voting period.

Best regards,
Dimitris Zacharopoulos.

On 13/2/2017 9:18 μμ, Ryan Sleevi via Public wrote:
> Pursuant to the consensus on 
> https://cabforum.org/pipermail/public/2017-February/009530.html about 
> the nature of changes during the discussion period, and the request 
> from Gervase on 
> https://cabforum.org/pipermail/public/2017-February/009618.html to 
> adjust what represents the Baseline agreement, this adjusts the 
> effective date from 1 April to 24 August. While individual programs 
> may choose to enact or enforce requirements prior to that, as the 
> Baseline Requirements capture the effective point of common agreement 
> of the bare minimum security levels, it seems appropriate that this 
> Ballot accurately reflect that.
>
>
> Ballot 185 - Limiting the Lifetime of Certificates
>
> The following motion has been proposed by Ryan Sleevi of Google, Inc 
> and endorsed by Josh Aas of ISRG and Gervase Markham of Mozilla to 
> introduce new Final Maintenance Guidelines for the "Baseline 
> Requirements Certificate Policy for the Issuance and Management of 
> Publicly-Trusted Certificates" and the "Guidelines for the Issuance 
> and Management of Extended Validation Certificates"
>
> -- MOTION BEGINS --
> Modify Section 6.3.2 of the "Baseline Requirements Certificate Policy 
> for the Issuance and Management of Publicly-Trusted Certificates" as 
> follows:
>
> Replace Section 6.3.2, which reads as follows:
> """
> 6.3.2. Certificate Operational Periods and Key Pair Usage Periods
>
> Subscriber Certificates issued after the Effective Date MUST have a 
> Validity Period no greater than 60 months.
> Except as provided for below, Subscriber Certificates issued after 1 
> April 2015 MUST have a Validity Period
> no greater than 39 months.
>
> Until 30 June 2016, CAs MAY continue to issue Subscriber Certificates 
> with a Validity Period greater than 39
> months but not greater than 60 months provided that the CA documents 
> that the Certificate is for a system or
> software that:
> (a) was in use prior to the Effective Date;
> (b) is currently in use by either the Applicant or a substantial 
> number of Relying Parties;
> (c) fails to operate if the Validity Period is shorter than 60 months;
> (d) does not contain known security risks to Relying Parties; and
> (e) is difficult to patch or replace without substantial economic outlay
> """
>
> with the following text:
> """
> 6.3.2. Certificate Operational Periods and Key Pair Usage Periods
>
> Subscriber Certificates issued on or after 24 August 2017 MUST NOT 
> have a Validity Period greater than three hundred and ninety-eight 
> (398) days.
>
> Subscriber Certificates issued prior to 24 August 2017 MUST NOT have a 
> Validity Period greater than thirty-nine (39) months.
> """
>
> Modify Section 9.4 of the "Guidelines for the Issuance and Management 
> of Extended Validation Certificates" as follows:
>
> Replace Section 9.4, which reads as follows:
> """
> 9.4. Maximum Validity Period For EV Certificate
>
> The validity period for an EV Certificate SHALL NOT exceed twenty 
> seven months. It is RECOMMENDED that EV
> Subscriber Certificates have a maximum validity period of twelve months.
> """
>
> with the following text:
> """"
> 9.4 Maximum Validity Period for EV Certificate
>
> EV Certificates issued on or after 24 August 2017 MUST NOT have a 
> Validity Period greater than three hundred and ninety-eight (398) days.
>
> EV Certificates issued prior to 24 August 2017 MUST NOT have a 
> Validity Period greater than twenty seven (27) months.
> """
> -- MOTION ENDS --
>
> Ballot 185 - Limiting the Lifetime of Certificates
> Status: Final Maintenance Guideline
>
> Review Period:
> Start Time: 2017-02-10 00:00:00 UTC
> End Time: 2017-02-17 00:00:00 UTC
>
> Vote for Approval:
> Start Time: 2017-02-17 00:00:00 UTC
> End Time: 2017-02-24 00:00:00 UTC
>
> Votes must be cast by posting an on-list reply to this thread on the 
> Public Mail List.
>
> A vote in favor of the ballot 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 ballot 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.
>
>
> _______________________________________________
> Public mailing list
> Public at cabforum.org
> https://cabforum.org/mailman/listinfo/public

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.cabforum.org/pipermail/public/attachments/20170220/7a5fbf99/attachment-0003.html>