[Smcwg-public] Ballot SMC01v3: Final Guideline for “S/MIME Baseline Requirements” - 3.2.4.2 Validation of individual identity

Tue Oct 25 14:03:56 UTC 2022

Hi Adriano:

Again, the requirement that RA agents “have access to information” about the security features of accepted forms of ID comes from ETSI TS 119 461.

It seems a reasonable stipulation.

Regards, Stephen

From: Smcwg-public <smcwg-public-bounces at cabforum.org> On Behalf Of Adriano Santoni via Smcwg-public
Sent: Tuesday, October 25, 2022 1:56 AM
To: SMIME Certificate Working Group <smcwg-public at cabforum.org>
Subject: [Smcwg-public] Ballot SMC01v3: Final Guideline for “S/MIME Baseline Requirements” - 3.2.4.2 Validation of individual identity

Yes, and for the same reason I propose to zap the following sentence also found in §3.2.4.2:

   The CA or RA registration agent SHALL have access to authoritative sources of information on
   document appearance and validation for forms of identity document accepted by the CA.

   That might perhaps be appropriate for legally binding digital signature certificates (e.g. eIDAS qualified), but for S/MIME certificates it's an exaggeration.

   I have filed issue 190 on github to fix these two aspects:

   https://github.com/cabforum/smime/issues/190

   Adriano

   Il 24/10/2022 17:39, Pedro FUENTES ha scritto:

   Hello Adriano,

   Thanks for bringing this up. I must confess that I oversaw that line too… and I totally agree with your views.

   There are methods for remote vetting that are based on document capture and face recognition that are largely sufficient for S/MIME certificates… This requirement for video identifications could be seen as reasonable for certificates used for qualified digital signatures, but for this is totally overkill here.

   BR/P

      On 24 Oct 2022, at 17:33, Adriano Santoni via Smcwg-public <smcwg-public at cabforum.org<mailto:smcwg-public at cabforum.org>> wrote:

      All,

      I apologize for raising doubts at the very "last minute", but since the SMC BR are about to be put to the vote, I wanted to give them a complete re-reading and I noticed a passage that leaves me a little perplexed.

      Maybe this aspect was discussed at length, but then I missed that discussion - sorry about that (in case).

      Under "3.2.4.2 Validation of individual identity" we have the following sentence:

         The CA or RA MAY use manual (in person) or remote procedures. A remote process SHALL ensure that the Applicant has the document in hand and presents the document in real‐time in front of a camera.

      Where did we borrow "in real-time" from? Not from the TLS BR nor from EVGL, it seems.

      What's the rationale for that? It seems too demanding, to me, for S/MIME certificates.

      Several CAs that I am aware of are doing individual identity verification (for S/MIME certificates) based on a Photo ID and a selfie (showing both the Applicant and his/her Photo ID), and this latter is not required to be taken in "real time".

      I am therefore a bit surprised that all the people here agree on this "in real time" which implies the non-compliance of current procedures and the need to move to more complex and more expensive procedures. Seems a bit excessive for S/MIME certificates.

      Adriano

      Il 14/10/2022 20:12, Stephen Davidson via Smcwg-public ha scritto:

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         Ballot SMC01v3: Final Guideline for “S/MIME Baseline Requirements”

         Note: the voting period for this ballot will commence following the SMCWG session at the upcoming CA/B Forum face-to-face Meeting 57.

         Purpose of Ballot:

         The S/MIME Certificate Working Group was chartered to discuss, adopt, and maintain policies, frameworks, and standards for the issuance and management of Publicly-Trusted S/MIME Certificates.  This ballot adopts a new “S/MIME Baseline Requirements” that includes requirements for verification of control over email addresses, identity validation for natural persons and legal entities, key management and certificate lifecycle, certificate profiles for S/MIME Certificates and Issuing CA Certificates, as well as CA operational and audit practices.

         An S/MIME Certificate for the purposes of this document can be identified by the existence of an Extended Key Usage (EKU) for id-kp-emailProtection (OID: 1.3.6.1.5.5.7.3.4) and the inclusion of a rfc822Name or an otherName of type id-on-SmtpUTF8Mailbox in the subjectAltName extension in the Certificate.

         The following motion has been proposed by Stephen Davidson of DigiCert and endorsed by Martijn Katerbarg of Sectigo and Ben Wilson of Mozilla.

         In accordance with the By-Laws, the discussion period has been extended with the distribution of this new version of the ballot, incorporating content that arose during the discussion period including regarding the use of suspension and updating ETSI references in section 8.2.

         Charter Voting References

         Section 5.1 (“Voting Structure”) of the SMCWG Charter says:

         In order for a ballot to be adopted by the SMCWG, two-thirds or more of the votes cast by the Certificate Issuers must be in favor of the ballot and more than 50% of the votes cast by the Certificate Consumers must be in favor of the ballot. At least one member of each class must vote in favor of a ballot for it to be adopted. Quorum is the average number of Member organizations (cumulative, regardless of Class) that have participated in the previous three (3) SMCWG Meetings or Teleconferences (not counting subcommittee meetings thereof).

         — MOTION BEGINS —

         This ballot adopts the “Baseline Requirements for the Issuance and Management of Publicly-Trusted S/MIME Certificates” (“S/MIME Baseline Requirements”) as Version 1.0.0.

         The proposed S/MIME Baseline Requirements may be found at https://github.com/cabforum/smime/pull/178/files or the attached document.  A redline of changes since the SMC01 Ballot discussion started may be found at https://github.com/cabforum/smime/compare/28c0b904fe54f1c5f6c71d18c4786a3e02c76f52...b1ff7867dc85392e4c57b1993ed571e61e34dee2

         The SMCWG Chair or Vice-Chair is permitted to update the Relevant Dates and Version Number of the S/MIME Baseline Requirements to reflect final dates.

         — MOTION ENDS —

         This ballot proposes a Final Guideline. The procedure for approval of this ballot is as follows:

         Discussion (7+ days)

         Start Time: 14 October 2022 14:00 ET (US Eastern)

         End Time: not before 21 October 2022 14:00 ET (US Eastern)

         Vote for approval (7 days)

         Start Time: To be confirmed

         End Time: To be confirmed

         IPR Review (60 days)

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