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

Tue Jan 16 15:40:30 UTC 2018

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>; CA/Browser Forum Public
Discussion List <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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