[cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

Thu Jan 18 23:51:52 MST 2018

Hi

Buypass, Entrust Datacard and GlobalSign have been working on some text to strengthen 3.2.2.4.1 instead of removing it - find the draft text below. The draft was discussed in the Validation Working Group meeting yesterday. We would like to offer this as an amendment to Ballot 218.

We (and some other CAs as well) are concerned about the short transition period in Ballot 218. In order to change systems, validation procedures etc. we believe any transition period should be at least 10 weeks (as long as the security risk exposed is low).

Regards
Mads

3.2.2.4.1 Validating the Applicant as a Domain Name Registrant
Conforming the Applicant's control over the FQDN by validating the Applicant as the Domain Name Registrant by verifying that:

1.       The name of the Domain Name Registrant matches the Applicant's name AND

2.       Additional information about the Domain Name Registrant in the WHOIS meet the following requirements:

                               i.            The Registrant's postal address in the WHOIS belongs to the Applicant. CAs MUST verify this by matching it with one of the Applicant's addresses in: (a) a QGIS, QTIS, or QIIS; or (b) a Verified Professional Letter.
Note: Address details in the WHOIS are required to use this option. Address details must include at a minimum the Country and either Locality, State or Province. OR

                             ii.            The WHOIS contains the Registration (or similar) Number assigned to the Applicant by the Incorporating or Registration Agency in its Jurisdiction of Incorporation or Registration as appropriate. CAs MUST verify this by matching the Registration Number in the WHOIS with the Applicant's Registration Number in a QGIS or a QTIS.
Additionally, this method may only be used if:
1. The CA authenticates the Applicant's identity under BR Section 3.2.2.1 and the authority of the Applicant Representative under BR Section 3.2.5, OR
2. The CA authenticates the Applicant's identity under EV Guidelines Section 11.2 and the agency of the Certificate Approver under EV Guidelines Section 11.8; OR
3. The CA is also the Domain Name Registrar, or an Affiliate of the Registrar, of the Base Domain Name.

Note: Once the FQDN has been validated using this method, the CA MAY also issue Certificates for other FQDNs that end with all the labels of the validated FQDN. This method is suitable for validating Wildcard Domain Names.

This revised version of BR 3.2.2.4.1 shall apply to domain validations occurring on or after June 1, 2018.

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Tim Hollebeek via Public
Sent: onsdag 17. januar 2018 00:13
To: Tim Hollebeek <tim.hollebeek at digicert.com>; CA/Browser Forum Public Discussion List <public at cabforum.org>; Bruce Morton <Bruce.Morton at entrustdatacard.com>; Jeremy Rowley <jeremy.rowley at digicert.com>
Subject: Re: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

Also, whatever improvements you propose to 3.2.5 (which we might support), our incident report covered  a case of non-compliance with the current rules, so it does not in any way demonstrate a weakness in the current rules.

It would be best not to confuse unrelated issues.

-Tim

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Tim Hollebeek via Public
Sent: Tuesday, January 16, 2018 3:55 PM
To: Bruce Morton <Bruce.Morton at entrustdatacard.com<mailto:Bruce.Morton at entrustdatacard.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>; Jeremy Rowley <jeremy.rowley at digicert.com<mailto:jeremy.rowley at digicert.com>>
Subject: Re: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

Ok, thanks for the update.

-Tim

From: Bruce Morton [mailto:Bruce.Morton at entrustdatacard.com]
Sent: Tuesday, January 16, 2018 3:43 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>; Jeremy Rowley <jeremy.rowley at digicert.com<mailto:jeremy.rowley at digicert.com>>
Subject: RE: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

Hi Tim,

A few CAs are working on some text to improve 3.2.2.4.1. We also think that 3.2.5 needs to be improved which may also be an improvement to support your incident report which discusses 3.2.5.

Hopefully text will be available for review in the next day or so.

Thanks, Bruce.

From: Tim Hollebeek [mailto:tim.hollebeek at digicert.com]
Sent: January 16, 2018 10:41 AM
To: Bruce Morton <Bruce.Morton at entrustdatacard.com<mailto:Bruce.Morton at entrustdatacard.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>; Jeremy Rowley <jeremy.rowley at digicert.com<mailto:jeremy.rowley at digicert.com>>
Subject: RE: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

I was told you guys were going to be providing text that improved method 1.  It now sounds like you think method 1 was good for the last 20 years, and will continue to be good for ... how long?  Has your position changed?

-Tim

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Bruce Morton via Public
Sent: Monday, January 15, 2018 9:20 AM
To: Jeremy Rowley <jeremy.rowley at digicert.com<mailto:jeremy.rowley at digicert.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: Re: [cabfpub] [EXTERNAL] Verification of Domain Contact and Domain Authorization Document

I'm following up on the original message to remove validation methods 3.2.2.4.1  and 3.2.2.4.5.

We validate a large percentage of certificate requests using 3.2.2.4.1. It is highly used with our enterprise clients and works great if you know your customer.  We would like to continue using this practice and are open to updating the BRs to help ensure that the three step methodology using 3.2.2.1, 3.2.2.4.1 and 3.2.5 is sound.

As background method 3.2.2.4.1 is probably the oldest domain validation method used. Until December 2017, I am not aware of any reported incidents. DigiCert appears to be the first to report an incident. After rereading the message below and reviewing the other messages, I cannot determine if any certificates were mississued. It would be great to get more details or review an incident report. This is important as we would like to correct the issues rather than eliminating 3.2.2.4.1 items 1 an 2.

So here is a question for DigiCert: were you reporting certificate misissuance using 3.2.2.4.1? If yes, will DigiCert be posting an Incident Report on the Mozilla Dev Security Policy list using Mozilla's standard report form, as is customary when reporting certificate misissuance?

We really need to understand the problem statement and review some real use cases. We need to see how 3.2.2.4.1 was combined with 3.2.2.1 and 3.2.5. How was the registrant verified? What Reliable Method of Communication was used?

We believe that:
-          3.2.2.1 can be used to securely identify the applicant
-          3.2.2.4.1 can be used to verify that the registrant is the applicant or an affiliate of the applicant
-          3.2.5 can be securely used to verify that an employee of the applicant has authorized the issuance of the certificate

We would like to continue to work with the Validation Working Group to find new text to improve these processes.

Thanks, Bruce.

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Jeremy Rowley via Public
Sent: December 19, 2017 4:30 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: [EXTERNAL][cabfpub] Verification of Domain Contact and Domain Authorization Document

Hi all,

When reviewing the Symantec validation methods and the customers using each method, I found an alarming number of customers verified under 3.2.2.4.1 (Verification of a Domain Contact) or 3.2.2.4.5 (Domain Authorization Document) where the domain is not technically associated with the entity. These two methods need improvement or removal as the way they are currently lacks sufficient controls to associate the domain verification with the actual certificate approver. I've had too many calls with customers explaining re-verification where the domain holder didn't understand that a cert issued for the domain. Although the organization verification was successfully complete, the only tie between the domain and organization is a call to the organization that happened within the last years to approve the account for issuance. I wanted to bring it up here because I've always thought these methods were less desirable than others. I think other large CAs use this method quite a bit so I'm hoping to get clarity on why these methods are permitted when the domain verification seems more "hand-wavy" than other methods.

Method 3.2.2.4.1 permits a CA to issue a certificate if the certificate is an EV or OV cert. With EV certificates, there is a call to a verified telephone number that confirms the requester's affiliation with the organization. I can see this method working for EV.  For OV certificates, there is a reliable method of communication that confirms the account holder as affiliated with the organization.  Unlike EV, for OV certs there is no tie between the requester and their authority to request a certificate. Once the organization is verified, the BRs permit auto-issuance for any domain that reflects an affiliation with the verified entity for up to 825 days. There's no notice to the domain contact that the certificate was requested or approved.  Perhaps this is sufficient as the account has been affiliated with the organization through the reliable method of communication and because CT will soon become mandatory.

Method 3.2.2.4.5 permits a CA to issue a certificate using a legal opinion letter for the domain. Unfortunately the BRs lack clear requirements about how the legal opinion letter is verified. If I want a cert for Google.com and the CA is following the bare minimum, all I need to do is copy their letterhead and sign the document. Magically, a certificate can issue.  This method lacks a lot of controls of method 1 because there is no requirement around verification of the company. I can list as many domains in the letter as I'd like provided the entity listed in the corresponding WHOIS's letterhead is used.

I'm looking to remove/fix both of these methods as both these methods lack the necessary controls to ensure that the verification ties to the domain holder. These methods probably should have been removed back when we passed 169/182. Would anyone being willing to endorse a ballot killing these or making some necessary improvements?

Jeremy

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