[cabfpub] [EXTERNAL] Ballot 221: Two-Factor Authentication and Password Improvements

Tim Hollebeek tim.hollebeek at digicert.com
Thu Mar 29 23:00:45 UTC 2018

Good question, Bruce.


My intent in this ballot is that the ballot is permissive immediately.  As
of the effective date, CAs that are able to do so can adopt sane policies,
instead of the currently required insane policies.


My intent is also to recognize that it may take some CAs longer to make that
transition . up to two years.  I don't think that's a bad thing, it's just a
consequence of the fact that some of them are operated by large, complicated
organizations that are being audited to a variety of sometimes conflicting


It is also worth mentioning that Mozilla policy, which CAs are required to
comply with at all times, says [2.1 (3)]:


"enforce multi-factor authentication for all accounts capable of causing
certificate issuance or performing Registration Authority or Delegated Third
Party functions, or implement technical controls operated by the CA to
restrict certificate issuance through the account to a limited set of
pre-approved domains or email addresses;"


I'm not horribly inclined to help out people who are out of compliance with
Mozilla policy; instead I'd prefer to harmonize the BRs with Mozilla policy
on this issue so that the BRs are a one stop shop for compliance
requirements.  I find the handful of bespoke requirements in various root
program requirements annoying and hard to follow, and I have more time to
follow them than most CAs do.


I'd appreciate if people pointed out any text in the ballot that is
inconsistent with these principles, so we can fix the ballot.  I have no
illusions that the Network Security WG and I got this right on the first
try.  Please look closely at the ballot and offer constructive improvements
if you spot problems.




From: Bruce Morton [mailto:Bruce.Morton at entrustdatacard.com] 
Sent: Thursday, March 29, 2018 5:44 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com>; CA/Browser Forum Public
Discussion List <public at cabforum.org>
Subject: RE: [EXTERNAL][cabfpub] Ballot 221: Two-Factor Authentication and
Password Improvements




As this ballot may require a CA to make a technical change or change a
procedure, should we state a future effective date to allow CAs to ensure
they are compliant?




From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Tim Hollebeek
via Public
Sent: March 28, 2018 3:26 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org
<mailto:public at cabforum.org> >
Subject: [EXTERNAL][cabfpub] Ballot 221: Two-Factor Authentication and
Password Improvements



Ballot 221: Two-Factor Authentication and Password Improvements


Purpose of Ballot: The Network Security Working Group met a number of times

improve the Network Security Guidelines requirements around authentication,

specifically by requiring two-factor authentication, and improving the

requirements in line with more recent NIST guidelines.


While CAs are encouraged to improve their password requirements as soon as 

possible, a two year grace period is being given to allow organizations to 

develop and implement policies to implement the improved requirements,

since some organizations may have to simultaneously comply with other

compliance frameworks that have not been updated yet and are based on older

guidance about passwords.


The following motion has been proposed by Tim Hollebeek of DigiCert and

by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.




This ballot modifies the "Network and Certificate System Security

as follows, based upon Version 1.1:


In the definitions, add a definition for Multifactor Authentication:


"Multi-Factor Authentication: An authentication mechanism consisting of two

more of the following independent categories of credentials (i.e. factors)

verify the user's identity for a login or other transaction: something you

(knowledge factor), something you have (possession factor), and something

are (inherence factor).  Each factor must be independent.  Certificate-based

authentication can be used as part of Multifactor Authentication only if the

private key is stored in a Secure Key Storage Device."


Add a definition for Secure Key Storage Device:


"Secure Key Storage Device: A device certified as meeting at least FIPS

level 2 overall, level 3 physical, or Common Criteria (EAL 4+)."


In section 1.j., capitalize Multi-Factor Authentication, and strike the 

parenthetical reference to subsection 2.n.(ii).


In section 2.f., add "(for accountability purposes, group accounts or shared

role credentials SHALL NOT be used)" after "authenticate to Certificate


Change section 2.g. to read:


"g. If an authentication control used by a Trusted Role is a username and

    then, where technically feasible, implement the following controls:

  i.           For accounts that are accessible only within Secure Zones or
High Security 

               Zones, require that passwords have at least twelve (12)

  ii.          For accounts that are accessible from outside a Secure Zone
or High Security 

               Zone, require Multi-Factor Authentication, with passwords
that have at least 

               eight (8) characters and are not be one of the user's
previous four (4) 

               passwords; and implement account lockout for failed access
attempts in 

               accordance with subsection k;

  iii.        When developing password policies, CAs SHOULD take into
account the password 

               guidance in NIST 800-63B Appendix A.

  iv.         If passwords are required to be changed periodically, that
period SHOULD be 

               at least two years.  Effective April 1, 2020, if passwords
are required to 

               be changed periodically, that period SHALL be at least two


In section 2.h., change "Require" to "Have a policy that requires"


In section 2.i., change "Configure" to "Have a procedure to configure"


Change section 2.k. to read:


"k. Lockout account access to Certificate Systems after no more than five
(5) failed access attempts, provided that this security measure:

  i.           is supported by the Certificate System,

  ii.          Cannot be leveraged for a denial of service attack, and

  iii.        does not weaken the security of this authentication control;"


Change section 2.n. to read:


"Enforce Multi-Factor Authentication for all Trusted Role accounts on

Systems (including those approving the issuance of a Certificate, which

applies to Delegated Third Parties) that are accessible from outside a
Secure Zone

or High Security Zone; and"




The procedure for approval of this ballot is as follows:


Discussion (7+ days)


Start Time: 2018-03-28  15:30:00 EDT


End Time: after 2018-04-04 15:30:00 EDT


Vote for approval (7 days)


Start Time: TBD


End Time: TBD

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