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

[Ryan Sleevi]

On Fri, Jan 19, 2018 at 1:51 AM, Mads Egil Henriksveen via Public <
public at cabforum.org> wrote:

> 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.
>

As Geoff has noted, this substantially weakens the requirements, to a level
unacceptable and non-equivalent to the existing methods. It also apparently
fails to understand both the underlying risks and concerns.

While I appreciate Buypass, Entrust, and GlobalSign working on such text,
I'll note that it lacks the necessary assurances, and also lacks the
necessary information to mitigate the risk for site operators.

Such certificates issued under these conditions should not be considered
trustworthy, as they do not provide assurance for domain control.
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