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

Kirk Hall Kirk.Hall at entrustdatacard.com
Tue May 22 16:39:44 MST 2018

Bylaw 2.4(a) says the following: “***If the Draft Guideline Ballot is proposing a Final Maintenance Guideline, such ballot will include a redline or comparison showing the set of changes from the Final Guideline section(s) intended to become a Final Maintenance Guideline, and need not include a copy of the full set of guidelines.  Such redline or comparison shall be made against the Final Guideline section(s) as they exist at the time a ballot is proposed, and need not take into consideration other ballots that may be proposed subsequently, except as provided in Section 2.4(j) below.”

I’m inclined to agree with Wayne, and it’s certainly hard to evaluate the ballot language without pulling out a copy of the NetSec Requirements first to see the context and what was changed.

Tim, Dimitris, and Neal – what do you think?  Is the form of Ballot 221 compliant with the Bylaws?  Do you want to ditch this ballot (we don’t have a quorum yet) and start again, including a red-line or comparison showing the changes from the current NetSec Requirements?

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Wayne Thayer via Public
Sent: Tuesday, May 22, 2018 2:00 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org>; Tim Hollebeek <tim.hollebeek at digicert.com>
Subject: [EXTERNAL]Re: [cabfpub] Voting Begins: Ballot 221: Two-Factor Authentication and Password Improvements

I'm unable to locate a redline of the changes in this final version of the ballot, making it difficult to vote. Is this not a "Draft Guideline Ballot" that should be clearly labeled as proposing a Final Maintenance Guideline, and that requires a redline be provided?

- Wayne

On Tue, May 22, 2018 at 11:45 AM Blunt, Dave via Public <public at cabforum.org<mailto:public at cabforum.org>> wrote:
Amazon votes YES on Ballot 221.

From: Public [mailto:public-bounces at cabforum.org<mailto:public-bounces at cabforum.org>] On Behalf Of Tim Hollebeek via Public
Sent: Thursday, May 17, 2018 2:48 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: [cabfpub] Voting Begins: 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 to
improve the Network Security Guidelines requirements around authentication,
specifically by requiring two-factor authentication, and improving the password
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, especially
since some organizations may have to simultaneously comply with other
compliance frameworks that have not been updated yet and are based on older NIST
guidance about passwords.

The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.


This ballot modifies the “Network and Certificate System Security Requirements”
as follows, based upon Version 1.1:

In the definitions, add a definition for Multi-Factor Authentication:

"Multi-Factor Authentication: An authentication mechanism consisting of two or
more of the following independent categories of credentials (i.e. factors) to
verify the user’s identity for a login or other transaction: something you know
(knowledge factor), something you have (possession factor), and something you
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."

Capitalize all instances of the defined term "Multi-Factor Authentication".

Add a definition for Secure Key Storage Device:

"Secure Key Storage Device: A device certified as meeting at least FIPS 140-2
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 Systems".

Change section 2.g. to read:

"g. If an authentication control used by a Trusted Role is a username and password,
    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) characters;
  ii.          For authentications which cross a zone boundary into a Secure Zone or High
               Security Zone, require Multi-Factor Authentication.  For accounts accessible
               from outside a Secure Zone or High Security Zone require 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 years."

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 Certificate
Systems (including those approving the issuance of a Certificate, which equally
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  15:00:00 EDT

End Time: 2018-05-17 17:45:00 EDT

Vote for approval (7 days)

Start Time: 2018-05-17 17:45:00 EDT

End Time: 2018-05-24 17:45:00 EDT

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