[cabfpub] REVISED Ballot 193 - 825-day Certificate Lifetimes (V2)

Fri Mar 3 02:42:55 UTC 2017

Dear Fellow CAB Forum Members,

When we posted Ballot 193 yesterday, it was intended to capture the consensus that emerged in the lengthy discussions around Ballot 185 and reduce maximum certificate and vetting data lifetime for DV and OV certs from the present 39 months to 27 months (or 825 days).  We also included certain conforming changes to make the language of the BRs and EV Guidelines match, and to reflect past Forum practices on reuse of certificate reuse.  We did not expect any issues.

However, some members did take issue with the conforming changes in emails posted to the list over the past day.  To be clear, these issues relate mainly to existing BR or EVGL provisions, and not to any new provisions we included in the first version of our ballot.  However, to open the way for maximum consensus on the main point of Ballot 193 – reducing cert and data lifetime from 39 months to 27 months – we have stripped those conforming changes from the attached revised “v2” version of Ballot 193 (see also the revised version pasted below).  We hope this earns 100% support for this ballot from all Forum members.

We did make a minor change to the language for BR 6.3.2 – Certificate Operational Periods.  The first version of the ballot said that from April 1, 2015 until March 1, 2018 the maximum cert validity period is 39 months – however, the current BRs allowed 60 month certs under the old rules until June 30, 2016 under limited circumstances.  So we have edited our changes to BR 6.3.2 to read that 39 month certs may be issued from July 1, 2016 until March 1, 2018.  Because both of those “start dates” for 39 month certs are in the past, this makes no real difference but is technically more correct.

In order to give people time to discuss the revised, streamlined “v2” version of Ballot 193, we are resetting the start of the discussion period to Friday, March 3 at 22:00 UTC, and adjusting the other dates accordingly.

Thanks for the great input – we listened, and modified Ballot 193 in response. Chris

*********

Ballot 193 - 825-day Certificate Lifetimes (REVISED v2 – March 2, 2017)

Purpose of Ballot: Recent Ballot 185 demonstrated a consensus among Forum members to reduce the maximum lifetime for DV and OV certificates from 39 months to 825 days (roughly 27 months).  This ballot reflects that consensus, and also reduces the maximum period for reuse of vetting data for DV and OV certificates from 39 months to 27 months.

The following motion has been proposed by Chris Bailey of Entrust Datacard and endorsed by the following CA/B Forum member representatives (listed in alphabetical order) Robin Alden of Comodo, Ben Wilson of DigiCert, and Doug Beattie of GlobalSign to introduce new Final Maintenance Guidelines for the "Baseline Requirements Certificate Policy for the Issuance and Management of Publicly-Trusted Certificates" (Baseline Requirements) and the "Guidelines for the Issuance and Management of Extended Validation Certificates" (EV Guidelines).

-- MOTION BEGINS --

BR 4.2.1. Performing Identification and Authentication Functions

The certificate request MAY include all factual information about the Applicant to be included in the Certificate, and such additional information as is necessary for the CA to obtain from the Applicant in order to comply with these Requirements and the CA’s Certificate Policy and/or Certification Practice Statement. In cases where the certificate request does not contain all the necessary information about the Applicant, the CA SHALL obtain the remaining information from the Applicant or, having obtained it from a reliable, independent, third‐party data source, confirm it with the Applicant. The CA SHALL establish and follow a documented procedure for verifying all data requested for inclusion in the Certificate by the Applicant.

Applicant information MUST include, but not be limited to, at least one Fully‐Qualified Domain Name or IP address to be included in the Certificate’s SubjectAltName extension.

Section 6.3.2 limits the validity period of Subscriber Certificates. The CA MAY use the documents and data provided in Section 3.2 to verify certificate information, provided that the CA obtained the data or document from a source specified under Section 3.2 no more than 825 days thirty‐nine (39) months prior to issuing the Certificate.

The CA SHALL develop, maintain, and implement documented procedures that identify and require additional verification activity for High Risk Certificate Requests prior to the Certificate’s approval, as reasonably necessary to ensure that such requests are properly verified under these Requirements.

If a Delegated Third Party fulfills any of the CA’s obligations under this section, the CA SHALL verify that the process used by the Delegated Third Party to identify and further verify High Risk Certificate Requests provides at least the same level of assurance as the CA’s own processes.

BR 6.3.2. Certificate Operational Periods and Key Pair Usage Periods

Subscriber Certificates issued after March 1, 2018 the Effective Date MUST have a Validity Period no greater than 825 days 60 months.  Subscriber Certificates issued after 1 July 2016 April 2015 but prior to 1 March 2018 MUST NOT have a Validity Period no greater than thirty-nine (39) 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.

EVGL 9.4. Maximum Validity Period For EV Certificate
The validity period for an EV Certificate SHALL NOT exceed 825 days twenty seven months. It is RECOMMENDED that EV Subscriber Certificates have a maximum validity period of twelve months.

-- MOTION ENDS --

The procedure for approval of this Final Maintenance Guideline ballot is as follows (exact start and end times may be adjusted to comply with applicable Bylaws and IPR Agreement):

BALLOT 193

Status: Final Maintenance Guideline

Start time (23:00 UTC)

End time (23:00 UTC)

Discussion (7 to 14 days)

March 3

March 10

Vote for approval (7 days)

March 10

March 17

If vote approves ballot: Review Period (Chair to send Review Notice) (30 days).

If Exclusion Notice(s) filed, ballot approval is rescinded and PAG to be created.

If no Exclusion Notices filed, ballot becomes effective at end of Review Period.

Upon filing of Review Notice by Chair

30 days after filing of Review Notice by Chair

From Bylaw 2.3: If the Draft Guideline Ballot is proposing a Final Maintenance Guideline, such ballot will include a redline or comparison showing the set of changes from the Final Guideline section(s) intended to become a Final Maintenance Guideline, and need not include a copy of the full set of guidelines.  Such redline or comparison shall be made against the Final Guideline section(s) as they exist at the time a ballot is proposed, and need not take into consideration other ballots that may be proposed subsequently, except as provided in Bylaw Section 2.3(j).

Votes must be cast by posting an on-list reply to this thread on the Public list.  A vote in favor of the motion 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/

In order for the motion 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.  Quorum is shown on CA/Browser Forum wiki.  Under Bylaw 2.2(g), at least the required quorum number must participate in the ballot for the ballot to be valid, either by voting in favor, voting against, or abstaining.
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