[Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot
Dimitris Zacharopoulos (HARICA)
dzacharo at harica.gr
Mon Dec 4 19:02:12 UTC 2023
FWIW, there are informational RFCs that include SHOULD requirements (I
didn't check for other informational RFCs that might contain SHALL
requirements). Take a look at RFC 8894
<https://datatracker.ietf.org/doc/html/rfc8894>.
I agree that there seems to be some ambiguity in the REQUIRED CP/CPS
structure but the entire reasoning behind using the "RFC 3647 format"
was to align CP and CPS documents so that comparisons can be made across
different CAs. If one CA reads that they must follow a 2-level structure
based on section 4, and another CA reads that they must follow the
structure of section 6 of the RFC, we're not meeting the goal for
alignment and easy comparisons.
Digicert's CPS seems to follow the structure of section 6 of RFC 3647.
Has anyone spotted a CPS claiming compliance with the TLS BRs that is
not following the section 6 structure of 3647?
If all existing public CAs follow the structure of section 6 of 3647 in
their CP/CPS documents, we can just clarify that the expectation is what
Ben mentioned in
https://github.com/BenWilson-Mozilla/pkipolicy/commit/1a94642cb95017cf382e4e93811db16a2342a806,
so that we address this ambiguity. We probably don't even need an
effective date if it causes no issue on existing CAs.
My point is that if we leave this open to interpretation, we can't
compare CP/CPS sections across multiple CAs efficiently, and this
defeats the whole purpose of the requirement to structure CP/CPS
documents according to RFC 3647. We might as well abandon the idea of
converting the EV Guidelines into that format.
I believe that the intent has always been to enforce a "stricter"
alignment. But if indeed there are deviations, I'd support some stricter
language to align CP/CPS documents according to section 6 of RFC 3647
even with a future effective date :)
Dimitris.
On 4/12/2023 7:27 μ.μ., Tim Hollebeek wrote:
>
> 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) <dzacharo at harica.gr>
> <mailto:dzacharo at harica.gr>
> *Sent:* Friday, December 1, 2023 1:04 PM
> *To:* Tim Hollebeek <tim.hollebeek at digicert.com>
> <mailto:tim.hollebeek at digicert.com>; Inigo Barreira
> <Inigo.Barreira at sectigo.com> <mailto:Inigo.Barreira at sectigo.com>
> *Cc:* CA/B Forum Server Certificate WG Public Discussion List
> <servercert-wg at cabforum.org> <mailto: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 <dzacharo at harica.gr>
> <mailto:dzacharo at harica.gr>
> *Sent:* Friday, December 1, 2023 10:48 AM
> *To:* Inigo Barreira <Inigo.Barreira at sectigo.com>
> <mailto:Inigo.Barreira at sectigo.com>
> *Cc:* 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>
> *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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