[cabfpub] Ballot 204: Forbid DTPs from doing Domain/IP Ownership Validation

[Gervase Markham]

*Ballot 204: 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 Ryan Sleevi of Google and Mike Reilly of Microsoft:

-- MOTION BEGINS --

This motion modifies the Baseline Requirements.

0) In section 1.6.1, augment the definition of "Delegated Third Party" as follows:

Delegated Third Party: A natural person or Legal Entity that is not the
CA*, and whose activities are not within the scope of the appropriate CA
audits,* 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.

1) In section 1.3.2, 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, replace the paragraph beginning "The CA SHALL confirm that" with the following:

"The CA SHALL confirm that, as of the date the Certificate issues, the CA has validated each Fully‐Qualified Domain Name (FQDN) listed in the Certificate using at least one of the methods listed below, or is within the Domain Namespace of a Fully-Qualified Domain Name (FQDN) that has been validated using at least one of the methods listed below (not including the method defined in section 3.2.2.4.8)."

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

4) In section 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"

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

6) 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 which are not Enterprise RAs, ".

-- MOTION ENDS --


The procedure for approval of this Final Maintenance Guideline ballot is
as follows:

 

BALLOT 204

Status: Final Maintenance Guideline

	

Start time (23:00 UTC)

	

End time (23:00 UTC)

Discussion (7 to 14 days)

	

27 June

	

4 July

Vote for approval (7 days)

	

4 July

	

11 July

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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