[Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot
Tim Hollebeek
tim.hollebeek at digicert.com
Mon Dec 4 17:27:05 UTC 2023
Yeah, the fact that the section 6 outline goes deeper than the actual described format in section 4 is annoying, and you’re right, it’s probably the source of these disagreements. I always look at section 4, because it has the actual guidance about what sort of information should be considered for inclusion.
This is what happens when people try to turn informational documents into normative requirements. You have to try to interpret what phrases like “are strongly advised to adhere”, which isn’t even a RFC 2119 SHOULD. And it can’t even be a SHOULD, because as an informational RFC, it is prohibited from having requirements, even SHOULDs! That’s why it’s written that way. Also, informational RFCs are not examined as closely for inconsistencies (because there are no requirements!) which is how divergences like section 4 vs 6 happen. It wasn’t intended to be used as a compliance document.
I still think what Inigo did is perfectly fine, although there are lots of other perfectly fine solutions, too. What we need to be discussing is what’s best for us, not RFC 3647 requires, because RFC 3647 has infinite leeway. As Aaron and I have been pointing out, you’ll find lots of divergences at level three, and there’s even lots of additional content in level two, just because a lot of newer content doesn’t really have a good fit in RFC 3647.
Now, that said, we might want to be more strict in the future, and if we choose to do so, we can be. I just don’t want people overstating what the rules actually are, because a lot of people’s time has been wasted enforcing RFC 3647 in a way that is far stricter than was ever intended (one of the reasons I’m so vocal on this issue is because I got this point of view from one of the original authors).
-Tim
From: Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr>
Sent: Saturday, December 2, 2023 5:26 AM
To: Tim Hollebeek <tim.hollebeek at digicert.com>; Inigo Barreira <Inigo.Barreira at sectigo.com>
Cc: 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 still have a disagreement so please allow me one more attempt to clarify my position because it seems you didn't check the links included in my previous post. I will copy some of that text here for convenience.
On 1/12/2023 11:31 μ.μ., Tim Hollebeek wrote:
No.
IETF has both Normative and Informative RFCs. While it is true that compliance with a Normative RFC is voluntary, if you do choose to comply, the RFC has requirements stated in RFC 2119 standards language that make it clear what the compliance rules are. Informative RFCs like 3647 do not have any normative requirements at all. They merely contain information.
“all sections of the RFC 3647 framework” is fine, this covers the sections enumerated in RFC 3647 section 4, which includes the TOP TWO levels of an outline in numbered form, e.g. the requirements for section 3.2 are described in RFC 3647 section 4.3.2. There is no RFC 3647 section 4.3.2.1, which proves my point. RFC 3647 only has a two level outline structure.
I think I might have a hint on our disconnect. RFC 3647 has an indicative Table of Contents in Chapter 6 (https://datatracker.ietf.org/doc/html/rfc3647#section-6) outlining the proposed CP/CPS sections and subsections using 3 levels.
Here is the text of the opening paragraph of that section (emphasis added):
This section contains a recommended outline for a set of provisions,
intended to serve as a checklist or (with some further development) a
standard template for use by CP or CPS writers. Such a common
outline will facilitate:
(a) Comparison of two certificate policies during cross-
certification or other forms of interoperation (for the purpose
of equivalency mapping).
(b) Comparison of a CPS with a CP to ensure that the CPS faithfully
implements the policy.
(c) Comparison of two CPSs.
In order to comply with the RFC, the drafters of a compliant CP or
CPS are strongly advised to adhere to this outline. While use of an
alternate outline is discouraged, it may be accepted if a proper
justification is provided for the deviation and a mapping table is
provided to readily discern where each of the items described in this
outline is provided.
The reason the CA/B Forum BRs were structured according to this outline was to assist with comparisons between CP/CPS documents of different CAs, making the review of these documents easier.
That's why you see sections like 1.5.4 "CPS approval procedures" in the BRs as an empty section with "No Stipulation". There are many such sections in the BRs, all coming from section 6 of RFC 3647.
I hope this is clearer now.
BR Section 2.2 needs to be re-written, as there are no materials required by RFC 3647 (because RFC 3647 contains no requirements). It needs to say something like “structured in accordance with RFC 3647 and MUST include all sections of the outline described in section 4” or something like that. What it says right now doesn’t capture the intent that you correctly summarized.
During the last couple of years reviewing CP/CPS documents, I saw some uniformity at least in Publicly Trusted CAs, and they all seem to follow the BRs structure which comes from the outline of section 6 of RFC 3647. However, it's not a bad idea to further clarify BR section 2.2 to better meet the expectations.
The MSRP language is better, I think I may have made all of these same points when it was being drafted, which is why it says “section and subsection” (two levels) and uses “structured according to” and not “complies with the requirements of”.
But anyway, this is all background that supports what I’ve been saying all along: BR 3.2 is a RFC 3647 section. BR 3.2.1 *is not* a RFC 3647 required section, nor is it even a section that is even mentioned in RFC 3647. If you don’t believe me, please go to RFC 3647, Section 4.3.2.1 and read what it says. OH, WAIT, IT DOESN’T EXIST! 😊
To my point, BR 3.2.1 IS an RFC 3647 required section as it is explicitly mentioned in the outline of section 6 of RFC 3647:
3.2.1 Method to prove possession of private key
Details about the contents of that section can be found in the first bullet of section 4.3.2 of RFC 3647 <https://datatracker.ietf.org/doc/html/rfc3647#section-4.3.2> .
Does that make more sense?
Dimitris.
-Tim
From: Dimitris Zacharopoulos (HARICA) <mailto:dzacharo at harica.gr> <dzacharo at harica.gr>
Sent: Friday, December 1, 2023 1:04 PM
To: Tim Hollebeek <mailto:tim.hollebeek at digicert.com> <tim.hollebeek at digicert.com>; Inigo Barreira <mailto:Inigo.Barreira at sectigo.com> <Inigo.Barreira at sectigo.com>
Cc: CA/B Forum Server Certificate WG Public Discussion List <mailto:servercert-wg at cabforum.org> <servercert-wg at cabforum.org>
Subject: Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot
Hi Tim,
None of the IETF standards set policy unless they are invited by some policy authority :) The BRs set such policy and "import" some documents, such as RFC 5280, 3647 and others.
The BRs in section 1.1 state:
These Requirements do not address all of the issues relevant to the issuance and management of Publicly-Trusted Certificates. In accordance with RFC 3647 and to facilitate a comparison of other certificate policies and CPSs (e.g. for policy mapping), this document includes all sections of the RFC 3647 framework. However, rather than beginning with a "no stipulation" comment in all empty sections, the CA/Browser Forum is leaving such sections initially blank until a decision of "no stipulation" is made
In addition, section 2.2 states (emphasis added):
The Certificate Policy and/or Certification Practice Statement MUST be structured in accordance with RFC 3647 and MUST include all material required by RFC 3647.
If you go back to the discussions when the CA/B Forum decide to align with the "RFC 3647 format", we agreed to include each and every section of the outline as a minimum set.
MRSP states in section 3.3 (5) (again, emphasis added):
5. all CPs, CPSes, and combined CP/CPSes MUST be structured according to RFC 3647 and MUST:
- include at least every section and subsection defined in RFC 3647;
- only use the words "No Stipulation" to mean that the particular document imposes no requirements related to that section; and
- contain no sections that are blank and have no subsections;
So, with all that considered, when we visit section 6 of RFC 3647 <https://datatracker.ietf.org/doc/html/rfc3647#section-6> ("the outline"), the expectation is to include each and every section and subsection of the outline (up to three levels).
CAs are free to add MORE sections and subsections as they desire, just like the BRs have done, but we can't escape or "hijack" an existing RFC 3647 section number. The outline contains a specific section labeled as "3.2.1 Method to prove possession of private key". That means we cannot re-use the number 3.2.1 for something else.
I hope this sounds reasonable to people.
Dimitris.
On 1/12/2023 6:51 μ.μ., Tim Hollebeek 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 <mailto:dzacharo at harica.gr> <dzacharo at harica.gr>
Sent: Friday, December 1, 2023 10:48 AM
To: Inigo Barreira <mailto:Inigo.Barreira at sectigo.com> <Inigo.Barreira at sectigo.com>
Cc: Tim Hollebeek <mailto:tim.hollebeek at digicert.com> <tim.hollebeek at digicert.com>; CA/B Forum Server Certificate WG Public Discussion List <mailto:servercert-wg at cabforum.org> <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 <mailto: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 <mailto:dzacharo at harica.gr> >
Enviado el: jueves, 30 de noviembre de 2023 13:16
Para: Inigo Barreira <Inigo.Barreira at sectigo.com <mailto:Inigo.Barreira at sectigo.com> >; Tim Hollebeek <tim.hollebeek at digicert.com <mailto:tim.hollebeek at digicert.com> >; 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
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 <mailto:Inigo.Barreira at sectigo.com> <Inigo.Barreira at sectigo.com>
Enviado el: martes, 29 de agosto de 2023 17:06
Para: Tim Hollebeek <mailto:tim.hollebeek at digicert.com> <tim.hollebeek at digicert.com>; Dimitris Zacharopoulos (HARICA) <mailto:dzacharo at harica.gr> <dzacharo at harica.gr>; CA/B Forum Server Certificate WG Public Discussion List <mailto:servercert-wg at cabforum.org> <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 <mailto:tim.hollebeek at digicert.com> >
Enviado el: martes, 29 de agosto de 2023 16:59
Para: Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr <mailto:dzacharo at harica.gr> >; 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: [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) < <mailto:dzacharo at harica.gr> dzacharo at harica.gr>
Sent: Tuesday, August 29, 2023 7:58 AM
To: Inigo Barreira < <mailto:Inigo.Barreira at sectigo.com> Inigo.Barreira at sectigo.com>; CA/B Forum Server Certificate WG Public Discussion List < <mailto:servercert-wg at cabforum.org> servercert-wg at cabforum.org>; Tim Hollebeek < <mailto:tim.hollebeek at digicert.com> 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 <https://lists.cabforum.org/pipermail/cscwg-public/2022-May/000795.html> ballot discussion period.
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 <mailto:tim.hollebeek at digicert.com> <tim.hollebeek at digicert.com>
Enviado el: lunes, 28 de agosto de 2023 19:49
Para: Inigo Barreira <mailto:Inigo.Barreira at sectigo.com> <Inigo.Barreira at sectigo.com>; CA/B Forum Server Certificate WG Public Discussion List <mailto:servercert-wg at cabforum.org> <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 < <mailto:servercert-wg-bounces at cabforum.org> 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 < <mailto:servercert-wg at cabforum.org> 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:
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/pull/440___.YXAzOmRpZ2ljZXJ0OmE6bzoyOGIxNWVhZGVmZDlkZTM0NjQzZTA3YTlmYTA2MzM5YTo2OmExZWM6NGZmMGEzM2U0ZWZjOTU4MTM1NWRkNjU3ZDE5YjU3Y2YxNzg1NWU0ZTVjYzkzY2NjM2M0MWU5MzEyYzJmZTQ0NzpoOkY> EVGs based on RFC3647 by barrini · Pull Request #440 · cabforum/servercert (github.com)
I am currently seeking two endorsers as well as any feedback on the ballot content itself (wording, effective dates, etc.).
Thanks,
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