[Servercert-wg] Discussion Period Begins: Ballot SC-061v3: New CRL Entries must have a Revocation Reason Code

Wed Feb 1 19:36:14 UTC 2023

Well, if Mozilla policy is wrong, we shouldn’t do the wrong thing just because it’s already in Mozilla policy.  It just needs we would need a bit of coordination with Mozilla to fix it.  However I don’t believe that’s necessary.

If you read the highlighted section Wendy posted, it’s pretty clear that RFC 5280 explicitly intends for superseded to be (mis)used in this manner.  Only the first unhighlighted part before the first “or” requires a request for a new certificate.

I share Aaron’s concern about the fact that this code means three things, two of them unrelated to the other, but unfortunately there doesn’t appear to be an IANA expansion point here to allow easy allocation of a new reason code.  However a short RFC could allocate a “compliance (9)” reason code and describe its proper use, if desired.

I hope I don’t have to state that the CABForum unilaterally choosing to use an undocumented reason code would be highly undesirable.

-Tim

From: Servercert-wg <servercert-wg-bounces at cabforum.org> On Behalf Of Aaron Gable via Servercert-wg
Sent: Wednesday, February 1, 2023 1:30 PM
To: Ben Wilson <bwilson at mozilla.com>; CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org>
Subject: Re: [Servercert-wg] Discussion Period Begins: Ballot SC-061v3: New CRL Entries must have a Revocation Reason Code

I will admit that I also don't *love* using Superseded for this purpose. However:

- There is no other revocation reason that is better: it's certainly not keyCompromise, affiliationChanged, cessationOfOperation, or privilegeWithdrawn. Using "unspecified" for such incidents also feels bad, as this lumps together CA-initiated revocations due to incidents with the majority of Subscriber-requested revocations.

- This ballot is attempting to incorporate current Mozilla requirements into the BRs. The MRSP currently says that Superseded should be used for this purpose. If the BRs choose to diverge from MRSP in this way, there will be contradictory requirements until one or the other changes.

- One could choose to interpret Superseded as, rather than a declaration that the CA already has replaced the certificate, a declaration that they're *willing* to. A no-fault revocation, for lack of a better term.

None of these are particularly strong arguments in favor of using Superseded for this purpose, but together I think they make it the most reasonable option.

Aaron

On Wed, Feb 1, 2023 at 10:01 AM Ben Wilson via Servercert-wg <servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>> wrote:
Thanks, Wendy.
Do others want to chime in on these points?
Ben

On Wed, Feb 1, 2023, 10:45 AM Wendy Brown - QT3LB-C <wendy.brown at gsa.gov<mailto:wendy.brown at gsa.gov>> wrote:
Superseded for these 2 reasons doesn't seem appropriate unless you also add that a new certificate was issued or at least requested, as a replacement.
6. The Certificate no longer complies with the requirements of [Section 6.1.5](#615-key-sizes) and [Section 6.1.6](#616-public-key-parameters-generation-and-quality-checking) (CRLReason #4, superseded);
and
12. 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 (CRLReason #4, superseded);

The definition isn't clear that a new cert has been issued (or even requested) based on the highlighted text - was it supposed to say that the CA issued a replacement certificate because it has reasonable evidence ....? Or should it just have ended with a . before the ", or the CA has ..."
  * **superseded (RFC 5280 CRLReason #4):** Indicates that the Certificate Subscriber has requested a new Certificate to replace an existing Certificate, or the CA has reasonable 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 or the CA has revoked the Certificate for compliance reasons such as the Certificate does not comply with these Baseline Requirements or the CA's CP or CPS;

Thanks,
Wendy

Wendy Brown
Supporting GSA
FPKIMA Technical Liaison
Protiviti Government Services
703-965-2990 (cell)

On Wed, Feb 1, 2023 at 12:22 PM Aaron Gable via Servercert-wg <servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>> wrote:
Wonderful, thank you! I have no further comments.

Aaron

On Tue, Jan 31, 2023 at 4:08 PM Ben Wilson <bwilson at mozilla.com<mailto:bwilson at mozilla.com>> wrote:
Thanks, Aaron - the numbering change was unintentional, so I fixed that, and I made other changes as requested.  See
https://github.com/BenWilson-Mozilla/servercert/commit/f1ed2357c6c9fe9bcedaec040582f872e0f519de <https://avanan.url-protection.com/v1/url?o=https%3A//github.com/BenWilson-Mozilla/servercert/commit/f1ed2357c6c9fe9bcedaec040582f872e0f519de&g=YWViMDQzOWVjODgwNjI1Nw==&h=N2Q0ODVjYjQ2NGM1ZTM4NWM0MDQ5MTlmYmMyZWIzY2Q1YzM0YjhhMjBkNzdlOGMzNTE5YmMzMjlmZWM3MWFlNw==&p=YXAzOmRpZ2ljZXJ0OmE6bzpjODAzMjllZGMxNDZmMjFjOWU4MzU3NDA0ZDE4M2MwMzp2MTpoOkY=>
Before I re-announce the discussion period, does anyone else have other changes that they would like to see?
Thanks,
Ben

On Mon, Jan 30, 2023 at 9:58 AM Aaron Gable <aaron at letsencrypt.org<mailto:aaron at letsencrypt.org>> wrote:
The current redline appears to undo the recent renumbering of section 4.9.1.1, causing it to have two different instances of paragraphs 1 through 5. These were renumbered in Ballot SC-56 Cleanup[1]. Can we please preserve the new numbering?

Additional notes:
- In 4.1.1.1 (1), perhaps "without specifying a CRLReason", rather than "without giving a reason"? A Subscriber might state "Please revoke this because I accidentally deleted the keys", in which case they are giving a reason, but the best revocation reason is still 0 (Unspecified). One might believe that Superseded is applicable in this case, but that revocation request does not necessarily indicate that the Subscriber has also replaced the certificate.
- A very minor comment, but there's inconsistent phrasing between the five revocation reasons in Section 7.2.2: the first begins "Indicates that..." while the others begin "It is intended to be used...". Can we give all five of these entries the same structure/phrasing?

Aaron

[1] https://github.com/cabforum/servercert/pull/401/files#diff-e0ac1bd190515a4f2ec09139d395ef6a8c7e9e5b612957c1f5a2dea80c6a6cfeR1214-R1224<https://avanan.url-protection.com/v1/url?o=https%3A//github.com/cabforum/servercert/pull/401/files%23diff-e0ac1bd190515a4f2ec09139d395ef6a8c7e9e5b612957c1f5a2dea80c6a6cfeR1214-R1224&g=M2UwYTBkMDgwN2Q5MTExYg==&h=MzhiZDYwZGUxNjhjYjlhZDgxOTkyNzVkMWRiZTUxODAzYmJkM2M4ZTc1MmZhMjkxYzBiZWJlYzE3YzQzY2NmYg==&p=YXAzOmRpZ2ljZXJ0OmE6bzpjODAzMjllZGMxNDZmMjFjOWU4MzU3NDA0ZDE4M2MwMzp2MTpoOkY=>

On Thu, Jan 19, 2023 at 1:55 PM Ben Wilson via Servercert-wg <servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>> wrote:
All,

This is version 3 of Ballot SC-061. I've moved some of the language down into section 7.2.2, and I've added back in two paragraphs that have been in the original Mozilla Root Store Policy regarding changing the reason code and revocation date for key compromise.  I also changed the compliance date to July 15, 2023. (The compliance date for CAs in Mozilla's program was Oct. 1, 2022.)

Purpose of Ballot SC-061 v.3

The purpose of this ballot is to modify sections 4.9.1.1 and 7.2.2 of the Baseline Requirements to incorporate the CRL reason codes that Mozilla has adopted in section 6.1.1 of the Mozilla Root Store Policy.

Motion

The following motion has been proposed by Ben Wilson of Mozilla and endorsed by David Kluge of Google Trust Services and Kiran Tummala of Microsoft.
—–Motion Begins—–
This ballot modifies sections 4.9.1.1 and 7.2.2 of the “Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates” as defined in the following redline, based on Version 1.8.6:
https://github.com/cabforum/servercert/compare/2c63814fa7f9f7c477c74a6bfbeb57e0fcc5dd5b..b1a3d9b491c9744a50a0e194678d76c639d6076b<https://avanan.url-protection.com/v1/url?o=https%3A//github.com/cabforum/servercert/compare/2c63814fa7f9f7c477c74a6bfbeb57e0fcc5dd5b..b1a3d9b491c9744a50a0e194678d76c639d6076b&g=ODQ0Mzc1NzQ3OGVhNjQyZg==&h=OGYwYjI0YmRmYjUwNzllMzU5MTkwOWQ4ZTZkYjEwMGVjN2IwNzg3ZDc5ZDA1ZDZkNjJlZjc0MzBkYjAzOTNlZA==&p=YXAzOmRpZ2ljZXJ0OmE6bzpjODAzMjllZGMxNDZmMjFjOWU4MzU3NDA0ZDE4M2MwMzp2MTpoOkY=>

 —–Motion Ends—–

This ballot proposes a Final Maintenance Guideline. The procedure for approval of this ballot is as follows:
Discussion (7+ days)
Start Time:  January 19, 2023 22:00 UTC
End Time: January 26, 2023 22:00 UTC

Vote for approval (7 days)
Start Time:  January 26, 2023 TBD
End Time: February 2, 2023 TBD
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