[cabfpub] Concerns regarding Mozilla Root Program/Baseline Requirements

Jeremy Rowley jeremy.rowley at digicert.com
Fri Aug 2 11:25:39 UTC 2013


As pointed out, a ten year or five year timeline for implementing change in
the industry is very long.  This was discussed extensively during adoption
of the BRs where we finally agreed to a five year timeline that would shift
to 3 years in 2015.  I'm strongly opposed to going back and re-evaluating
these timelines now, especially considering the amount of discussion,
debate, and compromise went into it last time. 

-----Original Message-----
From: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] On
Behalf Of Sigbjørn Vik
Sent: Friday, August 02, 2013 4:56 AM
To: public at cabforum.org
Subject: Re: [cabfpub] Concerns regarding Mozilla Root Program/Baseline
Requirements

I think the BRs are clear on what they require, and the EV definitions
clearly spell out that renewals and reissuances create newly issued
certificates. All new certificates require valid validity periods. While I
can understand that people may want to discuss if the rules are optimal, I
dislike CAs claiming ignorance of the rules, or exception to the rules since
they have done things differently in the past. If someone wants to claim the
rules are unclear, do so before assuming a particular interpretation, not
afterwards.

Opera is happy to work with the group to define optimal rules, but we
dislike CAs engaging in creative reinterpretation of the rules. If we can't
trust that CAs follow the rules decided upon, then the rules are close to
worthless.

In addition to reasons mentioned previously about why constrained validity
periods is a good idea, there is also the point about the web moving
forwards. For us to be able to upgrade requirements, ditch insecure
practices, and promise a secure experience in the future, we need to limit
the time limit of certificates today. This is basic insurance for the web in
the future. Any exceptions we carve out today, take away from this
insurance, and might end up costing us a lot. This is not a zero-sum game,
and decisions we make today might have serious consequences some years down
the road.

This discussion has also highlighted some other issues:
* It seems some CAs are happy to issue backdated certificates. We should
probably spell out that signing, issuance and first validity dates should
all be as close as possible, with a maximum discrepancy allowance.
* To be able to verify this, we should also require that any CT
registrations happen within that time limit. I will contact the CT team and
ask them to consider this.
* It seems audits don't catch CAs issuing certificates contrary to the BR.
What can we do to ensure that audits catch such issues?
* Does the CABForum need an explicit objective?

On 01-Aug-13 15:08, Rich Smith wrote:
> Taking Ryan's definition and subsequent logic would effectively 
> nullify all pre-BR agreements made with thousands of CA customers who 
> bought certificates for terms greater than the now allowed 60 months 
> max (and soon to be 39 month max).  My lay opinion is that such action 
> would open the CAs to lawsuits for breach of those agreements.

For CAs not to follow the BRs would presumably open them to lawsuits from
those who rely on the CAs for trust. For browsers not to follow due
diligence and best practices would presumably open them to lawsuits from
their customers. So if you care about potential lawsuits, the score is
2-1 for not issuing such certificates. However, I think potential lawsuits
are irrelevant. The goal of this group should be to secure the web, not to
ensure the short-term profits for individual members. (See the last point
above, about an objective.)

On 01-Aug-13 17:00, Steve Roylance wrote:
> [...] in 2015 when the
> industry flips to a 39 month max I believe from my engineering team we 
> would have had a similar issue to others, again due to the existing 
> contract precedence understanding that others have mentioned.

That would be strange. Since the BRs were adopted in November 2011, all CAs
have known (and been audited on) the fact that after 1 April 2015 the
maximum validity period is 39 months. For CAs today to sell certificates
valid more than 39 months past that date, and promise to reissue them at any
point would be shooting themselves in the foot.

--
Sigbjørn Vik
Opera Software
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