[Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot

Dimitris Zacharopoulos (HARICA) dzacharo at harica.gr
Fri Dec 1 18:11:32 UTC 2023



On 1/12/2023 7:27 μ.μ., Aaron Gable wrote:
> It's also worth noting that the Baseline Requirements also diverge 
> from RFC 3647 in this way: for example, Section 1.5 of RFC 3647 is 
> concerned with the contact information of the group /administering the 
> CP/CPS/, while Section 1.5(.2) of the BRs is concerned with contact 
> information of the group /operating the CA/.

The group /administrering /the CP/CPS can be included in section "1.5.2  
Contact person" along with what the BRs need for the group /operating 
/the CA. One does not prohibit the other.


> So trying to cleave too closely to the bulleted descriptions 
> inside RFC 3647 is unhelpful, imo.

I believe CAs are obligated by policy to include all bulleted section of 
section 6 of RFC 3647 (plus errata 
<https://www.rfc-editor.org/errata/rfc3647>).

>
> For whatever it's worth, I think that Section 11 of the current EVGs 
> could be renumbered wholesale to become Section 3.2, retaining its 
> subsections as-is, with few or no issues.

IMO ... as long as it doesn't conflict with sections/subsections of the 
outline of RFC 3647.

Dimitris.


>
> Aaron
>
> On Fri, Dec 1, 2023 at 8:51 AM Tim Hollebeek via Servercert-wg 
> <servercert-wg at cabforum.org> wrote:
>
>     This is unfortunately wrong.  There are lots of misconceptions
>     about RFC 3647 “compliance”.
>
>     The first point is that RFC 3647 is an INFORMATIONAL RFC.  You can
>     see this right at the top, where it says “Category:
>     Informational”. This means that it contains no requirements and
>     it’s impossible to be out of compliance with it.  This is why I
>     put quotes around “compliance”. Any requirements around it need to
>     come from elsewhere, for example, a root program requirement that
>     requires a particular document to be in RFC 3647 format.  But
>     that’s vague and informal, because 3647 doesn’t have requirements,
>     it just has an outline and suggested contents.  It’s not 100%
>     precise what “MUST be in RFC 3647 format” means, and we need to
>     just acknowledge that (specifying it precisely would be a colossal
>     waste of time).
>
>     So what does “RFC 3647 format” mean?  RFC 3647’s outline only
>     covers the first two levels.  So “Section 3.2: Initial Identity
>     Validation” is a RFC 3647 section header, and most reasonable
>     interpretations of “RFC 3647 format” would require it to exist
>     with that or a substantially similar name and contents.
>
>     Section 3.2.1, on the other hand, is not an RFC 3647 section. 
>     It’s common to have a third level of headers that mirror the
>     “bullet points” in the suggested content for the section, but
>     those are just unordered bullet lists in RFC 3647.  Claiming that
>     section 3.2.1 of a document in RFC 3647 must describe private key
>     protection goes beyond what RFC 3647 says.  Section 3.2 just
>     “contains the following elements”, so private key protection is
>     just one of several topics that one might discuss in section 3.2.
>     It could be section 3.2.1, but it could be elsewhere in 3.2, and
>     it’s perfectly fine for 3.2.1 to not exist, have different
>     content, etc.
>
>     Figuring out where section 11.1 goes is not trivial, but at first
>     glance, section 3.2 is not an unreasonable choice, and I can
>     understand why Inigo made it.  And there isn’t a compliance reason
>     why it can’t be section 3.2.1, if that’s what we want.
>
>     Of course, we could convert the recommended bulleted sections to a
>     numbered list of subsections (we often do elsewhere), in which
>     case section 3.2.1 could be “Private Key Protection” with contents
>     “No Stipulation”.  If we do that, I suggest we follow the rest of
>     the bullets as well.
>
>     Either way works.
>
>     -Tim
>
>     *From:* Dimitris Zacharopoulos <dzacharo at harica.gr>
>     *Sent:* Friday, December 1, 2023 10:48 AM
>     *To:* Inigo Barreira <Inigo.Barreira at sectigo.com>
>     *Cc:* Tim Hollebeek <tim.hollebeek at digicert.com>; CA/B Forum
>     Server Certificate WG Public Discussion List
>     <servercert-wg at cabforum.org>
>     *Subject:* Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647
>     format pre-ballot
>
>     We MUST comply with RFC 3647 which means that we must include
>     sections that are listed in the outline of 3647, and if we have
>     nothing to say, we leave it empty. We can't "hijack" the numbering
>     just because we have no requirements to describe.
>
>     That's my interpretation of the RFC 3647 compliance. Perhaps
>     others can chime in and state their opinion.
>
>
>     Thanks,
>
>     DZ.
>
>     Dec 1, 2023 14:50:23 Inigo Barreira <Inigo.Barreira at sectigo.com>:
>
>         Thanks Dimitris.
>
>         I think that strictly speaking, in RFC 3647 this section is
>         the 4.3.2 Initial Identity Validation and the first bullet is
>         about proving the possession of the private key, but there´s
>         no specific section other than the general approach that we´ve
>         implemented.
>
>         That said, the current EVG does not include anything about the
>         possession of the private key because that´s covered in the
>         TLS BRs so that section does not exist in the EVGs and
>         therefore I didn´t know how to avoid/implement it.
>
>         I decided to continue with the normal numbering for an easy
>         checking, so all 11 section is moved into section 3.2 and the
>         rest of the sub-numbers do not change (so 11.1 would be 3.2.1,
>         11.1.1 would be 3.2.1.1, etc.)
>
>         I understand your point but I think we can´t create a section
>         3.2.1 for private key possession because there´s no such a
>         text in the EVGs (and don´t think we should add anything new,
>         even a NA for that) and don´t know which other sections we can
>         create under 3.2 that can break the current equivalence, which
>         again was done for an easy comparison.
>
>         So, what would you suggest to “comply” with that? I don´t have
>         a clear idea.
>
>         Regards
>
>         *De:*Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>
>         *Enviado el:* jueves, 30 de noviembre de 2023 13:16
>         *Para:* Inigo Barreira <Inigo.Barreira at sectigo.com>; Tim
>         Hollebeek <tim.hollebeek at digicert.com>; CA/B Forum Server
>         Certificate WG Public Discussion List <servercert-wg at cabforum.org>
>         *Asunto:* Re: [Servercert-wg] SC-065: Convert EVGs into RFC
>         3647 format pre-ballot
>
>         CAUTION: This email originated from outside of the
>         organization. Do not click links or open attachments unless
>         you recognize the sender and know the content is safe.
>
>         Inigo,
>
>         As I am working to migrate the EV Guidelines into the EV Code
>         Signing Baseline Requirements I took a look at the mapping you
>         provided for the EV Guidelines and noticed that you are
>         proposing migration of EVG section 11.1 into section 3.2.1.
>         This particular section is labeled "Method to prove possession
>         of private key" in RFC 3647 so I don't think it is
>         appropriate. I think it's best to create new subsections under
>         3.2.
>
>         Thanks,
>         Dimitris.
>
>         On 8/9/2023 7:54 μ.μ., Inigo Barreira wrote:
>
>             Hi all,
>
>             Attached you´ll find the EVG v1.8.0 with comments in all
>             sections indicating where those sections, and the content,
>             have been moved into the new EVG RFC3647 format. So, with
>             this document, plus the redlined version, I hope you can
>             have now a clearer view of the changes done.
>
>             Let me know if you need anything else to clarify the new
>             version.
>
>             Regards
>
>             *De:*Inigo Barreira <Inigo.Barreira at sectigo.com>
>             <mailto:Inigo.Barreira at sectigo.com>
>             *Enviado el:* martes, 29 de agosto de 2023 17:06
>             *Para:* Tim Hollebeek <tim.hollebeek at digicert.com>
>             <mailto:tim.hollebeek at digicert.com>; Dimitris
>             Zacharopoulos (HARICA) <dzacharo at harica.gr>
>             <mailto:dzacharo at harica.gr>; CA/B Forum Server Certificate
>             WG Public Discussion List <servercert-wg at cabforum.org>
>             <mailto:servercert-wg at cabforum.org>
>             *Asunto:* RE: [Servercert-wg] SC-065: Convert EVGs into
>             RFC 3647 format pre-ballot
>
>             Thanks Dimitris and Tim.
>
>             I did something of that internally but didn´t reflect on
>             the document, so will try to reproduce to have it clearer.
>
>             OTOH, and as indicated in the PR, the whole section 11 has
>             been placed in section 3.2 keeping the rest of the
>             numbering. So, for example:
>
>             EVG EVG3647
>
>             11.1 3.2.1
>
>             11.1.1 3.2.1.1
>
>             11.1.2 3.2.1.2
>
>             11.1.3 3.2.1.3
>
>             11.2 3.2.2
>
>             11.2.1 3.2.2.1
>
>             ….. ….
>
>             11.13 3.2.13
>
>             11.14 3.2.14
>
>             11.14.1 3.2.14.1
>
>             11.14.2 3.2.14.2
>
>             11.14.3 3.2.14.3
>
>             Hope this can clarify the main difficult that I found in
>             the document, where to place it and how.
>
>             Regards
>
>             *De:*Tim Hollebeek <tim.hollebeek at digicert.com>
>             *Enviado el:* martes, 29 de agosto de 2023 16:59
>             *Para:* Dimitris Zacharopoulos (HARICA)
>             <dzacharo at harica.gr>; Inigo Barreira
>             <Inigo.Barreira at sectigo.com>; CA/B Forum Server
>             Certificate WG Public Discussion List
>             <servercert-wg at cabforum.org>
>             *Asunto:* RE: [Servercert-wg] SC-065: Convert EVGs into
>             RFC 3647 format pre-ballot
>
>             CAUTION: This email originated from outside of the
>             organization. Do not click links or open attachments
>             unless you recognize the sender and know the content is safe.
>
>             Yes, exactly.  I would like to see a list that shows that
>             EVG-classic section 1.4 is now in EVG-3647 section 4.1. 
>             Then I can look at where the new text landed, see how the
>             conversion was handled, we can all verify that nothing was
>             lost or left out, etc.
>
>             Without that, anyone attempting to review the document is
>             forced to recreate the mapping just to figure out where
>             everything went and that nothing was missed or put in the
>             wrong place.  Redlines are not sufficient when large
>             amounts of text are moving around to different places.
>
>             I’m saying this because from my spot-checking, the
>             conversion appears to be pretty good, and I’d like to be
>             able to do a final verification that it’s mostly correct
>             so I can endorse.
>
>             -Tim
>
>             *From:*Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr
>             <mailto:dzacharo at harica.gr>>
>             *Sent:* Tuesday, August 29, 2023 7:58 AM
>             *To:* Inigo Barreira <Inigo.Barreira at sectigo.com
>             <mailto:Inigo.Barreira at sectigo.com>>; CA/B Forum Server
>             Certificate WG Public Discussion List
>             <servercert-wg at cabforum.org
>             <mailto:servercert-wg at cabforum.org>>; Tim Hollebeek
>             <tim.hollebeek at digicert.com
>             <mailto:tim.hollebeek at digicert.com>>
>             *Subject:* Re: [Servercert-wg] SC-065: Convert EVGs into
>             RFC 3647 format pre-ballot
>
>             Hi Inigo,
>
>             You can take some guidance from previous successful
>             efforts to convert existing documents into RFC 3647
>             format. The latest attempt was in the Code Signing BRs
>             conversion in May 2022. Check out the mapping document and
>             the comments in the ballot discussion period
>             <https://lists.cabforum.org/pipermail/cscwg-public/2022-May/000795.html>.
>
>             For each existing section/paragraph, it would be nice to
>             have a comment describing where that existing language
>             will land in the converted document (destination). This
>             will allow all existing text to be accounted for.
>
>             During this process, you might encounter duplicate or
>             redundant text which needs to be flagged accordingly. You
>             might also get into some uncertainty as to which RFC3647
>             section is a best fit for existing text that might require
>             additional discussion.
>
>             I hope this helps.
>
>
>             Dimitris.
>
>             On 29/8/2023 12:42 μ.μ., Inigo Barreira via Servercert-wg
>             wrote:
>
>                 Hi Tim,
>
>                 See attached redlined and current versions. I just
>                 used what Martijn suggested yesterday but let me know
>                 if this is what you were looking for.
>
>                 Regards
>
>                 *De:*Tim Hollebeek <tim.hollebeek at digicert.com>
>                 <mailto:tim.hollebeek at digicert.com>
>                 *Enviado el:* lunes, 28 de agosto de 2023 19:49
>                 *Para:* Inigo Barreira <Inigo.Barreira at sectigo.com>
>                 <mailto:Inigo.Barreira at sectigo.com>; CA/B Forum Server
>                 Certificate WG Public Discussion List
>                 <servercert-wg at cabforum.org>
>                 <mailto:servercert-wg at cabforum.org>
>                 *Asunto:* RE: SC-065: Convert EVGs into RFC 3647
>                 format pre-ballot
>
>                 CAUTION: This email originated from outside of the
>                 organization. Do not click links or open attachments
>                 unless you recognize the sender and know the content
>                 is safe.
>
>                 Thanks for doing this Inigo … I know re-organizations
>                 like this are a lot of work and fall very much in the
>                 category of “important but not fun”.  So thanks for
>                 taking an initial stab at this.
>
>                 Is there a mapping that shows where all the original
>                 text ended up?  I think that’s going to be essential
>                 for people to be able to review this. I did some spot
>                 checking, and your conversion looks pretty good, but I
>                 wasn’t able to do a more detailed review without a
>                 mapping.
>
>                 -Tim
>
>                 *From:*Servercert-wg
>                 <servercert-wg-bounces at cabforum.org
>                 <mailto:servercert-wg-bounces at cabforum.org>> *On
>                 Behalf Of *Inigo Barreira via Servercert-wg
>                 *Sent:* Monday, August 28, 2023 5:20 AM
>                 *To:* CA/B Forum Server Certificate WG Public
>                 Discussion List <servercert-wg at cabforum.org
>                 <mailto:servercert-wg at cabforum.org>>
>                 *Subject:* [Servercert-wg] SC-065: Convert EVGs into
>                 RFC 3647 format pre-ballot
>
>                 Hello,
>
>                 The current Extended Validation Guidelines (EVGs) are
>                 written in a non-standardized format. For many years
>                 it has been discussed to convert this document into
>                 the RFC 3647 format and follow the standardized model
>                 for this type of documents.
>
>                 Given that this has been known for several years, I
>                 have prepared the following ballot text, which
>                 converts the EVGs into the RFC 3647 format:
>
>                 EVGs based on RFC3647 by barrini · Pull Request #440 ·
>                 cabforum/servercert (github.com)
>                 <https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/pull/440___.YXAzOmRpZ2ljZXJ0OmE6bzoyOGIxNWVhZGVmZDlkZTM0NjQzZTA3YTlmYTA2MzM5YTo2OmExZWM6NGZmMGEzM2U0ZWZjOTU4MTM1NWRkNjU3ZDE5YjU3Y2YxNzg1NWU0ZTVjYzkzY2NjM2M0MWU5MzEyYzJmZTQ0NzpoOkY>
>
>                 I am currently seeking two endorsers as well as any
>                 feedback on the ballot content itself (wording,
>                 effective dates, etc.).
>
>                 Thanks,
>
>                 _______________________________________________
>
>                 Servercert-wg mailing list
>
>                 Servercert-wg at cabforum.org
>                 <mailto:Servercert-wg at cabforum.org>
>
>                 https://lists.cabforum.org/mailman/listinfo/servercert-wg
>                 <https://lists.cabforum.org/mailman/listinfo/servercert-wg>
>
>     _______________________________________________
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>     Servercert-wg at cabforum.org
>     https://lists.cabforum.org/mailman/listinfo/servercert-wg
>
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