[Servercert-wg] Ballot SC-74 - Clarify CP/CPS structure according to RFC 3647

Clint Wilson clintw at apple.com
Fri May 10 18:19:42 UTC 2024 

Hi Tim,

> On May 10, 2024, at 8:52 AM, Tim Hollebeek via Servercert-wg <servercert-wg at cabforum.org> wrote:
> 
> Whether the comparison should be case sensitive or not is not a question of how “strict” the linter should be, but what the requirements are.  Linters MUST NOT make their own determinations as to what the requirements are, and SHOULD highlight cases like this where ambiguity may be present.  For example, it would be sensible to WARN that a value deviates in case from the correct value, and that the requirements are unclear whether that’s allowed (assuming SC-74 had passed in its current form).
>  
> However, I would question whether it’s actually even unclear at all.  It’s impossible to interpret the highlighted language into a, b, or c, because the language is completely silent on not just capitalization, but the titles themselves.  I interpret the highlighted language as saying you have to include at least every section and subsection, but it doesn’t matter what titles you give those sections or subsections (since there’s no relevant requirements).  That’s what the highlighted text says, and questions of whether it has to be capitalized the same way miss the fact that it doesn’t even say the same titles need to be used.
>  
> There are also some hilarious errors in 3647 if you look closely.  I think the best path forward would be something along the lines of:
>  
> MUST include at least every section and subsection defined in Appendix ZZ, and MUST use the section and subsection titles listed there
> The titles SHOULD be formatted, worded, capitalized and spelled the same way, and
> Errors in formatting or titling sections of a CPS are not grounds for revocation of affected certificates. 

Overall agreed with what’s stated here, except this part of the proposal. I do agree with what I believe your intent to be, but depending on how this is worded it seems it could lead to overly broad application (e.g. the error in titling “Non-verified subscriber information” results in a title of “Verified subscriber information”). Mostly just drawing attention to it as something that would need to be crafted somewhat carefully and perhaps would be preferable to have the MUST and SHOULD sections worded specifically enough that the intended allowance for errors in formatting or titling are encapsulated as clearly not part of the MUST requirement and clearly part of the SHOULD requirement. That approach would also avoid (I think) needing to consider the interaction of something like #3 with 4.9.1.2.(5).

Cheers,
-Clint

> And then explicitly list the outline we want in Appendix ZZ.  The outline should be very close to what 3647 says, to avoid unnecessary churn or deviation from IETF standards, but it would give us a chance to fix the obvious errors, and perhaps fix some historical baggage.
>  
> The resulting outline could be submitted back to IETF for publication as an update to 3647, which is starting to show its age.
>  
> -Tim
>  
> From: Servercert-wg <servercert-wg-bounces at cabforum.org <mailto:servercert-wg-bounces at cabforum.org>> On Behalf Of Roman Fischer via Servercert-wg
> Sent: Friday, May 10, 2024 4:20 AM
> To: CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org <mailto:servercert-wg at cabforum.org>>
> Subject: Re: [Servercert-wg] Ballot SC-74 - Clarify CP/CPS structure according to RFC 3647
>  
> Hi Wendy,
>  
> I would definitely go for c) because the documents are overall not standardized enough to do any kind of automatic parsing where a) or b) would maybe help.
>  
> Rgds
> Roman
>  
> From: Servercert-wg <servercert-wg-bounces at cabforum.org <mailto:servercert-wg-bounces at cabforum.org>> On Behalf Of Wendy Brown - QT3LB-C via Servercert-wg
> Sent: Donnerstag, 9. Mai 2024 16:58
> To: Aaron Gable <aaron at letsencrypt.org <mailto:aaron at letsencrypt.org>>
> 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] Ballot SC-74 - Clarify CP/CPS structure according to RFC 3647
>  
> OK - then I have a question for all those voting on SC74 (as an Associate member rep, I do not have a vote)
> How do you interpret the proposed new language:
> include at least every section and subsection defined in section 6 of RFC 3647
>  
> Does this mean:
> a) that the section and subsection headers have to exactly match the text in RFC 3647 including its use of capitalization, or 
> b) just that the words must be the same or 
> c) you just have to have the same numbering and the title can be slightly different as long as it covers the intended content?
>  
> Sorry to not have asked this during the discussion period, until I saw the output of the linter Aaron prepared, it didn't occur to me that anyone would have interpreted it as the capitalization had to match.
>  
> thanks,
> Wendy
>  
> Wendy Brown
> Supporting GSA
> FPKIMA Technical Liaison
> Protiviti Government Services
> 703-965-2990 (cell)
>  
>  
> On Thu, May 9, 2024 at 10:33 AM Aaron Gable <aaron at letsencrypt.org <mailto:aaron at letsencrypt.org>> wrote:
> I think that is a question to be taken up with the authors of SC-74, and with the root programs. In the interest of caution, I think this linting tool should err on the side of strictness. It is open source, however, so you are of course free to modify it for your own preferences.
>  
> Aaron
>  
> 
> On Thu, May 9, 2024, 04:57 Wendy Brown - QT3LB-C <wendy.brown at gsa.gov <mailto:wendy.brown at gsa.gov>> wrote:
> Aaron - 
> Can I suggest that maybe the comparison should be done in a case blind fashion?
> For example, requiring the headers for the subsections of 1.3 to have the second word lower case when it is common practice to refer to Certification Authorities as CAs and Registration Authorities as RAs, etc. just makes the document inconsistent. I understand the goal is to try to make comparisons easier, but requiring all Public Trusted CAs have these style inconsistencies in their own documentation seems like a step too far.
>  
> thanks,
> Wendy
>  
> Wendy Brown
> Supporting GSA
> FPKIMA Technical Liaison
> Protiviti Government Services
> 703-965-2990 (cell)
>  
>  
> On Wed, May 8, 2024 at 6:06 PM Aaron Gable via Servercert-wg <servercert-wg at cabforum.org <mailto:servercert-wg at cabforum.org>> wrote:
> Of course! Done: https://github.com/cabforum/servercert/issues/513 <https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/issues/513___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjhhYzY6ZmJmZTNhY2NmMGM2YmMyZjFhMzhmMjcwY2ExNDFkZTc3NGU5M2NkZDI4MzAyYjQwOWViMzNhMmJmZGRkMzAyMjpoOkY>
>  
> On Wed, May 8, 2024 at 8:37 AM Dimitris Zacharopoulos (HARICA) <dzacharo at harica.gr <mailto:dzacharo at harica.gr>> wrote:
> Thanks Aaron,
> 
> Would it be ok for you to create a GitHub issue <https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/issues___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmUwNjI6MzFkMjYyMTQ3NzdmNTM5NzExNDRlODRhYmQzZTcyM2RkMWU2MDk2YzExNzY3NDczZjRkM2FiNWYzYWIyZTYxMDpoOkY> to identify the specific sections that deviate in content? We might tackle that in a cleanup ballot. I don't think the capitalization is so much of a concern but if others think it is, please speak up :) 
> 
> 
> Dimitris.
> 
> On 8/5/2024 1:19 π.μ., Aaron Gable wrote:
> Two notes on this ballot, findings from our process for handling upcoming requirements:
>  
> 1) Let's Encrypt has created and open-sourced a tool <https://url.avanan.click/v2/___https:/github.com/letsencrypt/cp-cps/tree/d5b258a/tools/lint___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmNjYjI6MmViY2I4M2Y5MmJlNzU4MWM5YWJhMWRhYjk1YmFiNzc0NTdkOWI1OTA5ZWJiNTkzZGNmMGFjZjk2ZjY3NjhhYTpoOkY> for linting a CPS to confirm compliance with RFC 3647 Section 6 and Ballot SC-074. If you maintain your CPS document in markdown, it should be very simple to use or adapt to your particular situation.
>  
> 2) The Baseline Requirements themselves do not quite comply with RFC 3647 Section 6, with several section titles that deviate from that outline in either capitalization or actual content.
>  
> We hope this information is helpful to others,
> Aaron
>  
> On Thu, Apr 25, 2024 at 9:27 AM Dimitris Zacharopoulos (HARICA) via Servercert-wg <servercert-wg at cabforum.org <mailto:servercert-wg at cabforum.org>> wrote:
>  
> 
> SC-74 - Clarify CP/CPS structure according to RFC 3647
> 
> Summary
> 
> The TLS Baseline Requirements require in section 2.2 that:
> 
> "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."
> 
> The intent of this language was to ensure that all CAs' CP and/or CPS documents contain a similar structure, making it easier to review and compare against the BRs. However, there was some ambiguity as to the actual structure that CAs should follow. After several discussions in the SCWG Public Mailing List <https://url.avanan.click/v2/___https:/lists.cabforum.org/pipermail/servercert-wg/2023-November/004070.html___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjJmNjc6ZWM5ZWFhNDJkMmU0MGE0OGYxOWU1OWZkM2NkZmNiMTY3YmFjOWJlZDhiYTZiYzE5ZjBlZWM3MzI5YjYzNTM3NTpoOkY> and F2F meetings, it was agreed that more clarity should be added to the existing requirement, pointing to the outline described in section 6 of RFC 3647.
> 
> The following motion has been proposed by Dimitris Zacharopoulos (HARICA) and endorsed by Aaron Poulsen (Amazon) and Tim Hollebeek (Digicert).  
> You can view the github pull request representing this ballot here <https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/pull/503___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjNhZmM6MGQ5ZWY1YjVmZDBhMmU2MGRmODhlNjZlZDhlOWEzNzkwOGU2NjA3NTllYzg5MjJlYWViMTJmODQ5NzBiMThkNzpoOkY>. 
> 
> Motion Begins
> 
> MODIFY the "Baseline Requirements for the Issuance and Management of Publicly-Trusted TLS Server Certificates" based on Version 2.0.4 as specified in the following redline:
> 
> https://github.com/cabforum/servercert/compare/c4a34fe2292022e0a04ba66b5a85df75907ac2a2...f6a90e2a652fbb7a2d62a976b70f4af3adce8dae <https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/compare/c4a34fe2292022e0a04ba66b5a85df75907ac2a2...f6a90e2a652fbb7a2d62a976b70f4af3adce8dae___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmFjNTU6ZGE2MDMwNTE5MDk4OGQyZGQzOTI5ODkxMThhMDNhNzM5NDFhY2ZjYjUwZDE1YWUzNTYzZTE4MjcxZTY4ZDY3ODpoOkY>
> Motion Ends
> 
> This ballot proposes a Final Maintenance Guideline. The procedure for approval of this ballot is as follows:
> 
> Discussion (at least 7 days)
> 
> Start time: 2024-04-25 16:30:00 UTC
> End time: on or after 2024-05-02 16:30:00 UTC
> Vote for approval (7 days)
> 
> Start time: TBD
> End time: TBD
>  
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>  
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