[cabfpub] Reviving Ballot 213 - Revocation Timeline Extension

Wayne Thayer wthayer at mozilla.com
Wed May 16 13:00:18 MST 2018

Lat year, Jeremy proposed changes to section 4.9 of the BRs. I'd like to
revive that discussion with the following ballot proposal:

Summary of Changes:
* The first change creates a tiered timeline for revocations. The most
critical "reasons" still require revocation within 24 hours, but for many
others 24 hours becomes a SHOULD and the CA has 5 days before they MUST
revoke. This was the original motivation for the ballot, due in part to
last year's wave of misissued certs identified by linting tools.

* A new critical (24 hour) "reason for revocation" was added to address the
fact that there is currently no requirement for CAs to revoke a certificate
when requested by the domain name registrant. After considering some more
specific language that required CAs to follow to validate domain
control, I settled on the following more general "reason": "The CA obtains
evidence that the validation of domain authorization or control for any
Fully-Qualified Domain Name or IP address in the Certificate should not be
relied upon."

* Reason #10 states "The CA determines that any of the information
appearing in the Certificate is inaccurate or misleading;" This ballot
removes "or misleading" because that is a subjective judgement that could
effectively be used to justify censorship, as discussed at length in
relation to the "Stripe, Inc of Kentucky" EV certificates. [1]

* Current reasons #11 and #13 were removed from the section on subscriber
certificates because they address cases where the intermediate and/or root
must be revoked, so there isn't much sense (and some possible harm) in
requiring revocation of all the leaf certs.

* It requires CAs to disclose their problem reporting mechanisms in a
standard location: CPS section 1.5.2.

* Within 24 hours of receiving a problem report, the CA is now required to
report back to both the entity reporting the problem and the Subscriber on
the CA's findings, and to work with the reporter to establish a date by
which the CA will revoke the certificate.

This proposal has already been the subject of some debate on GitHub [2]. I
encourage you to review that and last year's discussions [3][4][5] on this

I would appreciate your review and feedback on this proposal.

I think this is a good topic for the London meeting - Kirk, can we reserve
a slot during the plenary session?



[2] https://github.com/wthayer/documents/pull/1#discussion_r185324648
[3] https://cabforum.org/pipermail/public/2017-August/thread.html#11880
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