[Smcwg-public] [External Sender] Re: Re: Allowing a signature made with an S/MIME IV or SV certificate as an additional individual identity validation method

Dimitris Zacharopoulos (HARICA) dzacharo at harica.gr
Thu May 16 12:12:11 UTC 2024



On 16/5/2024 3:06 μ.μ., Adriano Santoni via Smcwg-public wrote:
>
> At any rate, even with a digital signature made with an eIDAS 
> qualified certificate, you (the CA) cannot tell - in general - whether 
> the certificate was issued after identifying the Applicant with the 
> method described in eIDAS Article 24-1a, rather than 24-1b, or 24-1c, 
> or 24-1d. So it is quite possible that a certain an eIDAS qualified 
> certificate, taken at random, was issued with any of those 4 methods 
> as regards the individual identity vetting, AFAIK.
>

There has been a lot of debate on this issue, in ETSI ESI, FESA and 
ECATS. The general expectation is that if a TSP is not certain how the 
relied-upon certificate has been originally issued, to confirm that it 
was issued according to 24-1a or 24-1b, it should not accept it for 
24-1c. Different interpretations may exist but IMO the Regulation is 
clear on this issue.

Obviously the TSP knows how its own certificates have been issued and 
can easily apply 24-1c.


Dimitris.



> Adriano
>
>
> Il 16/05/2024 13:49, Dimitris Zacharopoulos (HARICA) ha scritto:
>> NOTICE: Pay attention - external email - Sender is dzacharo at harica.gr
>>
>>
>>
>>
>>
>> On 13/5/2024 5:03 μ.μ., Adriano Santoni via Smcwg-public wrote:
>>>
>>> Hi Martijn,
>>>
>>> I appreciate your concern, but would not the same concern also arise 
>>> with a digital signature made with an eIDAS qualified certificate?
>>>
>>
>> Hi Adriano, I missed this thread, apologies my earlier post didn't 
>> take this thread into account,
>>
>> If you are referring to eIDAS1 Art. 24-1c this renewal is allowed 
>> only if the relied-upon certificate was issued under Art. 24-1a or 
>> 24-1b. It cannot be used when a request is signed with a Qualified 
>> Certificate issued under Art. 24-1c otherwise we would fall into the 
>> situation that Martijn described.
>>
>>
>> Dimitris.
>>
>>> Anyway, it could be addressed by setting a time limit after which 
>>> re-validation by other means (to be specified) must be done, as you 
>>> suggest.
>>>
>>> Regards
>>>
>>> Adriano
>>>
>>>
>>> Il 13/05/2024 15:53, Martijn Katerbarg ha scritto:
>>>>
>>>> Hi Adriano,
>>>>
>>>> My immediate concern would be the scenario where say in 2024 
>>>> someone gets an S/MIME IV certificate issued based on current 
>>>> validation practices. Then in 2 years time, they renew based on 
>>>> their existing S/MIME certificate. Then in another two years, 
>>>> again, and yet again. Soon, we’ll be 10 years since the original 
>>>> validation took place, and ever since then the CA has relied upon 
>>>> an existing S/MIME certificate (or CA’s, if the Subscriber is 
>>>> switching to a different vendor) without any additional verification.
>>>>
>>>> Additionally, currently there’s no requirement to indicate in an SV 
>>>> certificate if an Enterprise RA was used or not.
>>>>
>>>> The second item could be solved by adding an indicator for that 
>>>> into the certificate (See 
>>>> https://github.com/cabforum/smime/issues/12), but I’m not sure how 
>>>> we’d solve the second one, and I’d be very hesitant on supporting 
>>>> something like that, without a proper time limit in place at which 
>>>> point re-validation would need to occur.
>>>>
>>>> Regards,
>>>>
>>>> Martijn
>>>>
>>>> *From:* Smcwg-public <smcwg-public-bounces at cabforum.org> on behalf 
>>>> of Adriano Santoni via Smcwg-public <smcwg-public at cabforum.org>
>>>> *Date:* Monday, 13 May 2024 at 15:32
>>>> *To:* SMIME Certificate Working Group <smcwg-public at cabforum.org>
>>>> *Subject:* [Smcwg-public] Allowing a signature made with an S/MIME 
>>>> IV or SV certificate as an additional individual identity 
>>>> validation method
>>>>
>>>> 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.
>>>>
>>>> Hi all,
>>>>
>>>> I already made the following proposal previously, both in writing 
>>>> here on the mailing list and also verbally during the last call (at 
>>>> the very last minutes as it was not on the agenda, sorry), but I 
>>>> don't see it mentioned in the call minutes of May 8 below, so I'll 
>>>> try to propose it again.
>>>>
>>>> Among the methods for the "Validation of individual identity" (SMBR 
>>>> 3.2.4.2), as part of the validation process of a request for an 
>>>> S/MIME IV certificate (or an SV certificate, where there is no 
>>>> Enterprise RA involved), I think it would make sense to admit - in 
>>>> addition to a digital signature based on an eIDAS compliant 
>>>> qualified certificate - also a digital signature based on another 
>>>> S/MIME IV or SV (BR-compliant) certificate of the applicant. This 
>>>> seems quite logical to me considering the rigor inherent in the 
>>>> validation requirements already established by the S/MIME BR to date.
>>>>
>>>> At least in the case of /renewal/, I think it would be completely 
>>>> logical and safe to accept a request signed by the applicant with 
>>>> his/her current S/MIME IV or SV certificate (the one soon to 
>>>> expire) without the need to perform a further "verification of 
>>>> individual identity" with other methods.
>>>>
>>>> If this idea for some reason doesn't seem practical or useful or 
>>>> safe enough, I'd like someone to explain their objections or concerns.
>>>>
>>>> Thank you all for your attention.
>>>>
>>>> Adriano
>>>>
>>>> Il 11/05/2024 22:02, Stephen Davidson via Smcwg-management ha scritto:
>>>>
>>>>     NOTICE: Pay attention - external email - Sender is
>>>>     0100018f693fd56b-e31b4721-c8ba-4ae7-a5bb-de9b42be70ce-000000 at amazonses.com
>>>>
>>>>
>>>>     ## Minutes of SMCWG
>>>>
>>>>     May 8, 2024
>>>>
>>>>     These are the Draft Minutes of the meeting described in the
>>>>     subject of this message. Corrections and clarifications where
>>>>     needed are encouraged by reply.
>>>>
>>>>     ## Attendees
>>>>
>>>>     Abhishek Bhat - (eMudhra), Adriano Santoni - (Actalis S.p.A.),
>>>>     Aggie Wang - (TrustAsia), Andrea Holland - (VikingCloud),
>>>>     Ashish Dhiman - (GlobalSign), Ben Wilson - (Mozilla), Bruce
>>>>     Morton - (Entrust), Clint Wilson - (Apple), Corey Bonnell -
>>>>     (DigiCert), Dimitris Zacharopoulos - (HARICA), Inaba Atsushi -
>>>>     (GlobalSign), Inigo Barreira - (Sectigo), Janet Hines -
>>>>     (VikingCloud), Judith Spencer - (CertiPath), Keshava Nagaraju -
>>>>     (eMudhra), Marco Schambach - (IdenTrust), Martijn Katerbarg -
>>>>     (Sectigo), Morad Abou Nasser - (TeleTrust), Mrugesh Chandarana
>>>>     - (IdenTrust), Nome Huang - (TrustAsia), Rebecca Kelly -
>>>>     (SSL.com), Renne Rodriguez - (Apple), Rollin Yu - (TrustAsia),
>>>>     Scott Rea - (eMudhra), Stefan Selbitschka - (rundQuadrat),
>>>>     Stephen Davidson - (DigiCert), Tadahiko Ito - (SECOM Trust
>>>>     Systems), Tathan Thacker - (IdenTrust), Tsung-Min Kuo -
>>>>     (Chunghwa Telecom), Wendy Brown - (US Federal PKI Management
>>>>     Authority)
>>>>
>>>>     ## 1. Roll Call
>>>>
>>>>     The Roll Call was taken.
>>>>
>>>>     ## 2. Read Antitrust Statement
>>>>
>>>>     The statement was read concerning the antitrust policy, code of
>>>>     conduct, and intellectual property rights agreement.
>>>>
>>>>     ## 3. Review Agenda
>>>>
>>>>     Minutes were prepared by Stephen Davidson.
>>>>
>>>>     ## 4. Approval of minutes from last teleconference
>>>>
>>>>     The minutes for the teleconference of April 24 were approved.
>>>>
>>>>     ## 5. Discussion
>>>>
>>>>     Stephen Davidson noted that Ballot SMC06 was in IPR until May
>>>>     11. See
>>>>     https://lists.cabforum.org/pipermail/smcwg-public/2024-April/000957.html
>>>>     <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Flists.cabforum.org%2Fpipermail%2Fsmcwg-public%2F2024-April%2F000957.html&data=05%7C02%7Cmartijn.katerbarg%40sectigo.com%7C708f7bd916fb456126ba08dc73512026%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638512039511762331%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=BHKcC9wi8xSZNIvCbF96gxjYbCI1d3s1SwRCdNpXMQw%3D&reserved=0>.
>>>>
>>>>     The WG discussed and approved the change of KeyFactor from an
>>>>     Interested Party to an Associate Member, Ellie Schieder as an
>>>>     Interested Party, and Posteo e.K as a Certificate Consumer.
>>>>
>>>>     The WG reviewed and discussed a ballot proposed by Martijn
>>>>     Katerbarg which would bring the S/MIME BR up to date with a
>>>>     recent ballot at the TLS BR for logging.   See more at
>>>>     https://github.com/cabforum/smime/issues/241
>>>>     <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fsmime%2Fissues%2F241&data=05%7C02%7Cmartijn.katerbarg%40sectigo.com%7C708f7bd916fb456126ba08dc73512026%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638512039511777400%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=zsu0bwRhIDoxPPlahVUlbI%2B%2FU7VdcyIjSfYHixo1JAk%3D&reserved=0>
>>>>
>>>>
>>>>     The WG had an extensive discussion regarding the migration to
>>>>     Multipurpose/Strict profiles.  Stephen noted that so far only
>>>>     two points had been raised by Certificate Issuers:
>>>>
>>>>       * Having adequate time (such as one year) to allow ERAs using
>>>>         integration time to adapt.
>>>>       * Concerns relating to the impact of shorter validity on
>>>>         deployments using tokens/smartcards.
>>>>
>>>>     Judith Spencer and Wendy Brown commented that the shorter
>>>>     validity had real impact on large (including public sector)
>>>>     deployments that use tokens/smartcards, including:
>>>>
>>>>       * limited storage on tokens/smartcards;
>>>>       * the increased burden of key exchange; and
>>>>       * and the costs of support for rekeying.
>>>>
>>>>     The question was raised whether it would be feasible to
>>>>     increase the validity for the Multipurpose profile to 1185 days
>>>>     in general, or in cases where tokens/smartcards are used. Clint
>>>>     Wilson spoke about the security and crypto agility benefits of
>>>>     shorter validity periods.  It was agreed this topic would be
>>>>     continued in Bergamo.
>>>>
>>>>     ## 6. Any Other Business
>>>>
>>>>     None.
>>>>
>>>>     ## 7. Next call
>>>>
>>>>     Next call:  the teleconference scheduled for May 22 has been
>>>>     cancelled. Next meeting is Bergamo F2F.
>>>>
>>>>     ## Adjourned
>>>>
>>>>
>>>>
>>>>     _______________________________________________
>>>>
>>>>     Smcwg-management mailing list
>>>>
>>>>     Smcwg-management at cabforum.org
>>>>
>>>>     https://lists.cabforum.org/mailman/listinfo/smcwg-management  <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Flists.cabforum.org%2Fmailman%2Flistinfo%2Fsmcwg-management&data=05%7C02%7Cmartijn.katerbarg%40sectigo.com%7C708f7bd916fb456126ba08dc73512026%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C638512039511787973%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=jyn4cbSuAbphPNeqicGutRFnz8pdQU98ccl8W0GxW8Q%3D&reserved=0>
>>>>
>>>
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