[cabfpub] Ballot 185 (Revised) - Limiting the Lifetime of Certificates

Tue Feb 21 18:37:11 UTC 2017

Symantec supports short certificate validity periods. We already offer customers the ability to issue certificates with validity less than 13 months. Customers use this option as best practice for high traffic and high value properties.

The May 1 effective date, and the August amended date proposed in the ballot do not allow customers and partners to transition to the new standards without material business impact and hardship. To enforce the new validity requirement:

••••••••• CAs need to update multiple applications/portals that issue certificates and this needs to be planned on their roadmap concurrent with CT and CAA deployments

••••••••• Partners need to change their certificate marketing and fulfillment applications and API integration with CAs

••••••••• Customers operating two and three year certificates need to change their internal policies, educate internal stakeholders and potentially hire IT staff to handle double or triple annual certificate workload

••••••••• Customers need to update any automation software that assists in procuring and deploying certificates; existing automated processes used to secure mission critical servers must be subject to adequate regression testing and signoff

••••••••• Automation often takes several months to fully deploy if not more than a year

••••••••• Complex ecosystems where certificates are distributed across thousands of devices cannot be frequently updated without serious business disruption

••••••••• Today customers can renew certificates up to 90 days in advance to ensure business continuity; with 12 month validity customers may end up renewing every 9 months

••••••••• The 90 day advance practice allows for: difficult to validate jurisdictions or situations, pre-production testing, change control advance notice SLAs, and reduced IT staffing

••••••••• Replacing existing multi-year validity certificates should be grandfathered with a transparent technical method to mark them compliant when replaced. Otherwise existing 2 and 3 year validity certificates cannot be replaced without potentially losing prepaid remaining validity at the time of replacement causing confusion, support calls, and pro-rated refunds

••••••••• Customers need to revisit their commercial contracts where they have prepaid for multi-year certificates and not yet received the product; this remains a common method of transacting in some markets and channels

••••••••• Non browser based applications/appliances that use TLS certificates need to plan for more frequent certificate deployments

••••••••• Substantive change to IT business practice needs to be communicated to enterprises before typical Q4 budget planning for the upcoming year

Symantec is open to proposals of 27 month validity for certificates provided that implementation timeline allows an orderly transition to the new requirements effective February 1, 2018 or later. Our impact analysis targets late November 2017 and therefore moves after annual IT holiday freeze.

Symantec votes “NO”.

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Ryan Sleevi via Public
Sent: Monday, February 13, 2017 2:18 PM
To: CABFPub <public at cabforum.org>
Cc: Ryan Sleevi <sleevi at google.com>
Subject: [cabfpub] Ballot 185 (Revised) - Limiting the Lifetime of Certificates

Pursuant to the consensus on https://cabforum.org/pipermail/public/2017-February/009530.html<https://clicktime.symantec.com/a/1/IDZTzBh9Jkzw-m-d-dSbRk1fwPuh4nIQPo8XSu6uUlk=?d=mCg4ahac7KIM9NNjlpjC4QhaKtSD8VUjo7oJlxsmafhWo9Fzv0AtpL9mKatOU0wLchvhgFIryRoRJ_tIqFt2qOCeTLzYX_TXK5qqcvGgBb6KDX6gAQB5zB8iD2qlxVId62GfuY84DnnEQhZ7V4IBuXNj6wEHRkyVtw9lrVoOtNKsh3fTOsBTO-1yiZ6pF92QgWZ4MiESulULIb1yuBSTmYbDGtZZFNJDTmo715ZogHP-2FEOTEo6PPoN2eWmuNC7egt_khRdf3UbUjIQPEZKheUDnzE41LRt0DwcUJ5znPZUAV7xJZwVEQX4dLtW9FdPA6IMAK5rnZGKjBs7j5LCCb5sHHJx37MhcaV61z217UkDXq9t2M5GTPdK6A52OQn9YJkzZBGZwYs5XwHJLoM7rN81tmPLMfjfAO5ySzINlaeyso5ELOeH8OBi5Fh7XNaoIuoEJprVSg%3D%3D&u=https%3A%2F%2Fcabforum.org%2Fpipermail%2Fpublic%2F2017-February%2F009530.html> about the nature of changes during the discussion period, and the request from Gervase on https://cabforum.org/pipermail/public/2017-February/009618.html<https://clicktime.symantec.com/a/1/9rqqU-PBgPCRihbl8M_SLx1ZPt96936DPTs8odxlIhM=?d=mCg4ahac7KIM9NNjlpjC4QhaKtSD8VUjo7oJlxsmafhWo9Fzv0AtpL9mKatOU0wLchvhgFIryRoRJ_tIqFt2qOCeTLzYX_TXK5qqcvGgBb6KDX6gAQB5zB8iD2qlxVId62GfuY84DnnEQhZ7V4IBuXNj6wEHRkyVtw9lrVoOtNKsh3fTOsBTO-1yiZ6pF92QgWZ4MiESulULIb1yuBSTmYbDGtZZFNJDTmo715ZogHP-2FEOTEo6PPoN2eWmuNC7egt_khRdf3UbUjIQPEZKheUDnzE41LRt0DwcUJ5znPZUAV7xJZwVEQX4dLtW9FdPA6IMAK5rnZGKjBs7j5LCCb5sHHJx37MhcaV61z217UkDXq9t2M5GTPdK6A52OQn9YJkzZBGZwYs5XwHJLoM7rN81tmPLMfjfAO5ySzINlaeyso5ELOeH8OBi5Fh7XNaoIuoEJprVSg%3D%3D&u=https%3A%2F%2Fcabforum.org%2Fpipermail%2Fpublic%2F2017-February%2F009618.html> to adjust what represents the Baseline agreement, this adjusts the effective date from 1 April to 24 August. While individual programs may choose to enact or enforce requirements prior to that, as the Baseline Requirements capture the effective point of common agreement of the bare minimum security levels, it seems appropriate that this Ballot accurately reflect that.

Ballot 185 - Limiting the Lifetime of Certificates

The following motion has been proposed by Ryan Sleevi of Google, Inc and endorsed by Josh Aas of ISRG and Gervase Markham of Mozilla to introduce new Final Maintenance Guidelines for the "Baseline Requirements Certificate Policy for the Issuance and Management of Publicly-Trusted Certificates" and the "Guidelines for the Issuance and Management of Extended Validation Certificates"

-- MOTION BEGINS --

Modify Section 6.3.2 of the "Baseline Requirements Certificate Policy for the Issuance and Management of Publicly-Trusted Certificates" as follows:

Replace Section 6.3.2, which reads as follows:

"""

6.3.2. Certificate Operational Periods and Key Pair Usage Periods

Subscriber Certificates issued after the Effective Date MUST have a Validity Period no greater than 60 months.

Except as provided for below, Subscriber Certificates issued after 1 April 2015 MUST have a Validity Period

no greater than 39 months.

Until 30 June 2016, CAs MAY continue to issue Subscriber Certificates with a Validity Period greater than 39

months but not greater than 60 months provided that the CA documents that the Certificate is for a system or

software that:

(a) was in use prior to the Effective Date;

(b) is currently in use by either the Applicant or a substantial number of Relying Parties;

(c) fails to operate if the Validity Period is shorter than 60 months;

(d) does not contain known security risks to Relying Parties; and

(e) is difficult to patch or replace without substantial economic outlay

"""

with the following text:

"""

6.3.2. Certificate Operational Periods and Key Pair Usage Periods

Subscriber Certificates issued on or after 24 August 2017 MUST NOT have a Validity Period greater than three hundred and ninety-eight (398) days.

Subscriber Certificates issued prior to 24 August 2017 MUST NOT have a Validity Period greater than thirty-nine (39) months.

"""

Modify Section 9.4 of the "Guidelines for the Issuance and Management of Extended Validation Certificates" as follows:

Replace Section 9.4, which reads as follows:

"""

9.4. Maximum Validity Period For EV Certificate

The validity period for an EV Certificate SHALL NOT exceed twenty seven months. It is RECOMMENDED that EV

Subscriber Certificates have a maximum validity period of twelve months.

"""

with the following text:

""""

9.4 Maximum Validity Period for EV Certificate

EV Certificates issued on or after 24 August 2017 MUST NOT have a Validity Period greater than three hundred and ninety-eight (398) days.

EV Certificates issued prior to 24 August 2017 MUST NOT have a Validity Period greater than twenty seven (27) months.

"""

-- MOTION ENDS --

Ballot 185 - Limiting the Lifetime of Certificates

Status: Final Maintenance Guideline

Review Period:

Start Time: 2017-02-10 00:00:00 UTC

End Time: 2017-02-17 00:00:00 UTC

Vote for Approval:

Start Time: 2017-02-17 00:00:00 UTC

End Time: 2017-02-24 00:00:00 UTC

Votes must be cast by posting an on-list reply to this thread on the Public Mail List.

A vote in favor of the ballot must indicate a clear 'yes' in the response. A vote against must indicate a clear 'no' in the response. A vote to abstain must indicate a clear 'abstain' in the response. Unclear responses will not be counted. The latest vote received from any representative of a voting Member before the close of the voting period will be counted. Voting Members are listed here: https://cabforum.org/members/<https://clicktime.symantec.com/a/1/rXwNqCZvMNcV59rOKx4iYxvWscu0zP1pPP8axkSuLyU=?d=mCg4ahac7KIM9NNjlpjC4QhaKtSD8VUjo7oJlxsmafhWo9Fzv0AtpL9mKatOU0wLchvhgFIryRoRJ_tIqFt2qOCeTLzYX_TXK5qqcvGgBb6KDX6gAQB5zB8iD2qlxVId62GfuY84DnnEQhZ7V4IBuXNj6wEHRkyVtw9lrVoOtNKsh3fTOsBTO-1yiZ6pF92QgWZ4MiESulULIb1yuBSTmYbDGtZZFNJDTmo715ZogHP-2FEOTEo6PPoN2eWmuNC7egt_khRdf3UbUjIQPEZKheUDnzE41LRt0DwcUJ5znPZUAV7xJZwVEQX4dLtW9FdPA6IMAK5rnZGKjBs7j5LCCb5sHHJx37MhcaV61z217UkDXq9t2M5GTPdK6A52OQn9YJkzZBGZwYs5XwHJLoM7rN81tmPLMfjfAO5ySzINlaeyso5ELOeH8OBi5Fh7XNaoIuoEJprVSg%3D%3D&u=https%3A%2F%2Fcabforum.org%2Fmembers%2F>

In order for the ballot to be adopted, two thirds or more of the votes cast by Members in the CA category and greater than 50% of the votes cast by members in the browser category must be in favor.

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