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

Tim Hollebeek tim.hollebeek at digicert.com
Wed May 23 05:33:56 MST 2018

Mike, it's a SHOULD, so we have two years to fix it.  I agree the wording is
awkward, it was hard to write.  I found words like minimum and maximum to be
very confusing as they would get misread as the other.  There was discussion
about this exact language, including at the face to face.  Your description
agrees with the intent, and is what I explained at the face to face in
Virginia.  Use great passwords, and DON'T overly frequently rotate them.  So
you guys are correctly understanding the requirement.


On the policies for zones, this is consistent with the guidance in NIST
SP800-63 that if all other things are equal, longer passwords are stronger.
So in zones with higher security requirements, we have higher length


Voting NO would prevent removal of the language that requires frequent
password changes.  Which means that bad practice continues for a bit longer.


The discussion period for this ballot was quite long.  I would encourage
people to not wait until the final draft and/or voting to analyze draft
ballots.  I would prefer not to tweak this ballot and revote it, but I'll do
that if needed.


I would have been willing to provide a redline to assist in voting if the
request had come in earlier, like not a day or two before voting ends.


There was an earlier incident this year where I had to correct the redline;
I'm currently erring on not including a redline if I'm not 100% (-epsilon)
sure that it agrees with the ballot text.


Some of you that have been around for a while remember that redlines used to
be uncommon.  The fact that they're common right now is a side effect of the
fact that I write most of the ballots.


Hope some or all of this helps.




From: Mike Reilly (GRC) [mailto:Mike.Reilly at microsoft.com] 
Sent: Tuesday, May 22, 2018 10:06 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com>; CA/Browser Forum Public
Discussion List <public at cabforum.org>
Subject: RE: Voting Begins: Ballot 221: Two-Factor Authentication and
Password Improvements


I'm having internal conversations with concerns regarding section iv which


" 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


Sorry I didn't catch this during the discussion period but the language
should be adjusted. A period of at least two years means you wait a minimum
of two years. Can we use words like maximum?


The reference to NIST SP 800-63 makes us think we want to emphasize stronger
passwords while minimizing the frequency with which those secrets are
changed. That is what the NIST guidance calls for. The language "if
passwords are required to be changed." also makes us think this. Basically,
password changes are optional, but if you require them to be changed, two
years is the minimum amount of time to wait before changing them.


Also, why have separate policies for different security zones? A
12-character password of seahawks2018 shouldn't be considered better than an
8 digit randomly generated one.


I agree with Wayne that a redlined version should be provided for a vote as
it's difficult to clearly see the changes.  I'm inclined to vote No at this
point and apologize for not looking harder at this in the discussion period.


Thanks, Mike


From: Public <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

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 Multi-Factor 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."


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

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 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


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  15:00:00 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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