[cabfpub] Ballot SC6 v3 - Revocation Timeline Extension

Wayne Thayer wthayer at mozilla.com
Mon Sep 10 11:54:15 MST 2018


This ballot entered the voting period late on Friday. Voting ends this
Friday 2018-09-14 at 20:00 UTC.

On Fri, Aug 31, 2018 at 12:51 PM Wayne Thayer <wthayer at mozilla.com> wrote:

> Here is version 3 of this ballot, incorporating changes to v2 suggested by
> Bruce and Ryan (thanks!).
>
> I noticed that our current bylaws have reverted back to a fixed-length
> discussion period, so I have changed this version to comply.
>
> ==========================================
>
> Ballot SC6 version 3: Revocation Timeline Extension
>
> Purpose of Ballot:
> Section 4.9.1.1 of the Baseline Requirements currently requires CAs to
> revoke a Subscriber certificate within 24 hours of identifying any of 15
> issues affecting the certificate. In cases where there is not an immediate
> threat of misuse of the certificate, this requirement can cause undue harm
> to a Subscriber that isn't capable of replacing the certificate prior to
> revocation. This ballot makes a number of improvements to the revocation
> rules imposed by the Baseline Requirements:
> * Primarily, it 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.
> * A new "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 3.2.2.4 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.
> * 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 and Subscriber to
> establish a date by which the CA will revoke the certificate.
>
> The following motion has been proposed by  Wayne Thayer of Mozilla and
> endorsed by Tim Hollebeek of DigiCert and Dimitris Zacharopoulos of Harica.
>
> --- MOTION BEGINS --- This ballot modifies the “Baseline Requirements for
> the Issuance and Management of Publicly-Trusted Certificates” as follows,
> based on Version 1.6.0:
>
> ** Modify the definition of Key Compromise as follows: **
> Key Compromise: A Private Key is said to be compromised if its value has
> been disclosed to an unauthorized person or an unauthorized person has had
> access to it.
>
> ** Modify Section 4.9.1 to read as follows: **
>
> 4.9.1.1 Reasons for Revoking a Subscriber Certificate
>
> The CA SHALL revoke a Certificate within 24 hours if one or more of the
> following occurs:
> 1. The Subscriber requests in writing that the CA revoke the Certificate;
> 2. The Subscriber notifies the CA that the original certificate request
> was not authorized and does not retroactively grant authorization;
> 3. The CA obtains evidence that the Subscriber's Private Key corresponding
> to the Public Key in the Certificate suffered a Key Compromise; or
> 4. 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.
>
> The CA SHOULD revoke a certificate within 24 hours and MUST revoke a
> Certificate within 5 days if one or more of the following occurs:
> 1. The Certificate no longer complies with the requirements of Sections
> 6.1.5 and 6.1.6;
> 2. The CA obtains evidence that the Certificate was misused;
> 3. The CA is made aware that a Subscriber has violated one or more of its
> material obligations under the Subscriber Agreement or Terms of Use;
> 4. The CA is made aware of any circumstance indicating that use of a
> Fully-Qualified Domain Name or IP address in the Certificate is no longer
> legally permitted (e.g. a court or arbitrator has revoked a Domain Name
> Registrant's right to use the Domain Name, a relevant licensing or services
> agreement between the Domain Name Registrant and the Applicant has
> terminated, or the Domain Name Registrant has failed to renew the Domain
> Name);
> 5. The CA is made aware that a Wildcard Certificate has been used to
> authenticate a fraudulently misleading subordinate Fully-Qualified Domain
> Name;
> 6. The CA is made aware of a material change in the information contained
> in the Certificate;
> 7. The CA is made aware that the Certificate was not issued in accordance
> with these Requirements or the CA's Certificate Policy or Certification
> Practice Statement;
> 8. The CA determines or is made aware that any of the information
> appearing in the Certificate is inaccurate;
> 9. The CA's right to issue Certificates under these Requirements expires
> or is revoked or terminated, unless the CA has made arrangements to
> continue maintaining the CRL/OCSP Repository;
> 10. Revocation is required by the CA's Certificate Policy and/or
> Certification Practice Statement; or
> 11. The CA is made aware of a demonstrated or proven method that exposes
> the Subscriber's Private Key to compromise, methods have been developed
> that can easily calculate it based on the Public Key (such as a Debian weak
> key, see http://wiki.debian.org/SSLkeys), or if there is clear evidence
> that the specific method used to generate the Private Key was flawed.
>
> 4.9.1.2 Reasons for Revoking a Subordinate CA Certificate
>
> The Issuing CA SHALL revoke a Subordinate CA Certificate within seven (7)
> days if one or more of the following occurs:
> 1. The Subordinate CA requests revocation in writing;
> 2. The Subordinate CA notifies the Issuing CA that the original
> certificate request was not authorized and does not retroactively grant
> authorization;
> 3. The Issuing CA obtains evidence that the Subordinate CA's Private Key
> corresponding to the Public Key in the Certificate suffered a Key
> Compromise or no longer complies with the requirements of Sections 6.1.5
> and 6.1.6;
> 4. The Issuing CA obtains evidence that the Certificate was misused;
> 5. The Issuing CA is made aware that the Certificate was not issued in
> accordance with or that Subordinate CA has not complied with this document
> or the applicable Certificate Policy or Certification Practice Statement;
> 6. The Issuing CA determines that any of the information appearing in the
> Certificate is inaccurate or misleading;
> 7. The Issuing CA or Subordinate CA ceases operations for any reason and
> has not made arrangements for another CA to provide revocation support for
> the Certificate;
> 8. The Issuing CA's or Subordinate CA's right to issue Certificates under
> these Requirements expires or is revoked or terminated, unless the Issuing
> CA has made arrangements to continue maintaining the CRL/OCSP Repository; or
> 9. Revocation is required by the Issuing CA's Certificate Policy and/or
> Certification Practice Statement.
>
> ** Modify section 4.9.3 as follows: **
>
> The CA SHALL provide a process for Subscribers to request revocation of
> their own Certificates. The process MUST be described in the CA's
> Certificate Policy or Certification Practice Statement. The CA SHALL
> maintain a continuous 24x7 ability to accept and respond to revocation
> requests and Certificate Problem Reports.
>
> The CA SHALL provide Subscribers, Relying Parties, Application Software
> Suppliers, and other third parties with clear instructions for reporting
> suspected Private Key Compromise, Certificate misuse, or other types of
> fraud, compromise, misuse, inappropriate conduct, or any other matter
> related to Certificates. The CA SHALL publicly disclose the instructions
> through a readily accessible online means and in section 1.5.2 of their CPS.
>
> ** Modify section 4.9.5 to read as follows: **
>
> Within 24 hours after receiving a Certificate Problem Report, the CA SHALL
> investigate the facts and circumstances related to a Certificate Problem
> Report and provide a preliminary report on its findings to both the
> Subscriber and the entity who filed the Certificate Problem Report.
>
> After reviewing the facts and circumstances, the CA SHALL work with the
> Subscriber and any entity reporting the Certificate Problem Report or other
> revocation-related notice to establish whether or not the certificate will
> be revoked, and if so, a date which the CA will revoke the certificate. The
> period from receipt of the Certificate Problem Report or revocation-related
> notice to published revocation MUST NOT exceed the time frame set forth in
> Section 4.9.1.1. The date selected by the CA SHOULD consider the following
> criteria:
> 1. The nature of the alleged problem (scope, context, severity, magnitude,
> risk of harm);
> 2. The consequences of revocation (direct and collateral impacts to
> Subscribers and Relying Parties);
> 3. The number of Certificate Problem Reports received about a particular
> Certificate or Subscriber;
> 4. The entity making the complaint (for example, a complaint from a law
> enforcement official that a Web site is engaged in illegal activities
> should carry more weight than a complaint from a consumer alleging that she
> didn't receive the goods she ordered); and
> 5. Relevant legislation.
> --- MOTION ENDS ---
>
> This ballot proposes a Final Maintenance Guideline.
>
> A comparison of the changes can be found at:
> https://github.com/cabforum/documents/compare/master...wthayer:patch-1
>
> The procedure for approval of this ballot is as follows:
> Discussion (7 days)
> Start Time: 2018-08-31  20:00 UTC
> End Time: 2018-09-07  20:00 UTC
> Vote for approval (7 days)
> Start Time: 2018-09-07  20:00 UTC
> End Time: 2018-09-14  20:00 UTC
>
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