[Servercert-wg] Ballot SC30: Disclosure of Registration / Incorporating Agency

[Entschew, Enrico]

Hi Ryan,
I have written my comments inline.
Thanks,
Enrico

Von: Ryan Sleevi <sleevi at google.com>
Gesendet: Tuesday, June 23, 2020 8:16 PM
An: Entschew, Enrico <e.entschew at d-trust.net>
Cc: CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org>
Betreff: Re: [Servercert-wg] Ballot SC30: Disclosure of Registration / Incorporating Agency



On Tue, Jun 23, 2020 at 1:52 PM Entschew, Enrico <e.entschew at d-trust.net<mailto:e.entschew at d-trust.net>> wrote:
Hallo,

I have no content-specific comments but I would like to suggest some changes to make it more readable for non-native English speakers.

Thanks! This is really appreciated.

I would also emphasize to use either SHALL or MUST to be more consistent.

Sure, this should have been "The CA MUST perform some action" and "The action SHALL be performed in this way". I think you went the other way (the CA SHALL do something), but it seems like the EVGs are more consistently that the CA MUST do something, and the something SHALL be a certain way.

Thanks for the explanation. I see your point.
-----------------
Changed:
(line 508) Effective as of 1 October 2020, the CA SHALL ensure that the Registration Number is valid according to at least one format disclosed by the CA for that applicable Registration Agency or Incorporating agency. The CA has to disclose a set of acceptable format or formats for Registration Numbers for the applicable Registration Agency or Incorporating Agency, as described in Section 11.1.3.

My worry here is that it loses the "optional" disclosure that some CAs felt was important. That is, the CA MAY choose to not disclose and/or restrict the Registration Number (e.g. some Registration/Incorporating Agencies don't disclose the format or intentionally discourage assuming a format).

I agree, it's worded a bit clunky as-is, but it's trying to capture that the enforcement is required, if, and only if, they've also disclosed a format. I'm wondering if you have any suggestions on how to preserve this optional nature. This seems important to get right, especially if your reword didn't preserve it as optional because you didn't read it as optional :)

Maybe:
This is required if the CA has disclosed a set of acceptable format or formats for Registration Numbers for the applicable Registration Agency or Incorporating Agency, as described in Section 11.1.3.

Changed:
(line 760) Effective as of 1 October 2020 the CA SHALL publicly disclose Agency Information about the Incorporating Agency or Registration Agency before using an Incorporating Agency or Registration Agency to fulfill these verification requirements. This SHALL be through an appropriate and readily accessible online means.

The current language was trying to mirror the Section 8.2.2 language regarding CP/CPSes. I thought that parallel (and to the BRs Section 2.2) would make this easier? I worry that "this" may be seen as ambiguous.

[…]
(line 765) * The acceptable forms or syntax of such Numbers, if the CA restricts the form or syntax of the Registration Number used by the Incorporating Agency or Registration Agency; and,

Yeah, this seems reasonable. The current wording was trying to highlight and address some CAs' concern about it being optional (see above).

[…]
-----------------

I hope you find this useful.

Thanks,
Enrico

Von: Servercert-wg <servercert-wg-bounces at cabforum.org<mailto:servercert-wg-bounces at cabforum.org>> Im Auftrag von Ryan Sleevi via Servercert-wg
Gesendet: Wednesday, June 17, 2020 1:32 AM
An: CA/B Forum Server Certificate WG Public Discussion List <servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>>
Betreff: [Servercert-wg] Ballot SC30: Disclosure of Registration / Incorporating Agency

This begins the discussion period for Ballot SC30: Disclosure of Registration / Incorporating Agency

Purpose of Ballot:

The EV Guidelines aim to ensure a consistent and repeatable level of validation for certificates, regardless of the CA performing the validation, providing Relying Parties consistency for all certificates complying with these Guidelines. Although the Guidelines attempt to specify objective requirements, areas remain that rely on a subjective determination by the CA. One such area is determining whether a given Incorporating Agency or Registration Agency fulfills these Requirements.

As currently specified, it's possible for one CA to make a determination that a given Registration Agency or Incorporating Agency does meet the requirements of the EV Guidelines, while a different CA determines that same Agency does not. As the reliability of the information validated within the Certificate is tied to the reliability of the data source used to verify this information, this inconsistency undermines the assurance that EV Certificates are meant to provide.

While there is utility in being able to identify precisely what datasource(s) were used with a given Certificate, this ballot does not involve such work. It merely seeks to ensure that, for any given Organization, it can be validated consistently and to the same degree, regardless of the CA, by working to achieve consistency among all CAs in their selection of data sources.

Much like the work to remove “Any other method” from the validation of domain names, ensuring consistency, transparency, and objectivity in validating domain names, this ballot is the first step to doing the same for organization information.

A potential roadmap of ballots to to address these issues involves:

  *   CAs publish the list of Registration Agencies / Incorporating Agencies they use (this ballot)
  *   Create an allowed list of Registration Agencies / Incorporating Agencies and associated values, along with a process for updating and adding new ones, and requiring issuance exclusively use Agencies on this list.
  *   If useful and relevant to Relying Parties, ensure each Certificate can be tied back to their Registration Agency / Incorporating Agency, such as disclosure within the Certificate itself, so they can unambiguously and uniquely determine the organization that has been validated.

A similar process may then be repeated for other forms of verification data sources, such as the QIIS, QTIS, and QGIS within the EV Guidelines, or the Reliable Data Sources within the Baseline Requirements.

This was originally drafted in https://github.com/sleevi/cabforum-docs/pull/11 , and as a pull request is available at https://github.com/cabforum/documents/pull/194

The following motion has been proposed by Ryan Sleevi of Google and endorsed by Ben Wilson of Mozilla and Dimitris Zacharopoulos of HARICA.

— MOTION BEGINS —

This ballot modifies the “Guidelines for the Issuance and Management of Extended Validation Certificates” (“EV Guidelines”) as follows, based on version 1.7.2:

ADD a paragraph to Section 9.2.4 of the EV Guidelines as defined in the following redline: https://github.com/cabforum/documents/compare/d5067bbbfb46906c65e476ef3d55dd3b2c505a09..33de720df2af6328922524e675f02cb4468a9609

ADD a paragraph to Section 9.2.5 of the EV Guidelines as defined in the following redline: https://github.com/cabforum/documents/compare/d5067bbbfb46906c65e476ef3d55dd3b2c505a09..33de720df2af6328922524e675f02cb4468a9609

ADD a Section 11.1.3 to the EV Guidelines as defined in the following redline: https://github.com/cabforum/documents/compare/d5067bbbfb46906c65e476ef3d55dd3b2c505a09..33de720df2af6328922524e675f02cb4468a9609

The Chair or Vice-Chair is permitted to update the Relevant Dates of the EV Guidelines as appropriate, such as in the following redline: https://github.com/cabforum/documents/compare/d5067bbbfb46906c65e476ef3d55dd3b2c505a09..33de720df2af6328922524e675f02cb4468a9609

— MOTION ENDS —

This ballot proposes a Final Maintenance Guideline.

The procedure for approval of this ballot is as follows:

Discussion (7+ days)
Start Time: 17-June 2020 00:00 UTC
End Time: 24-June 2020 12:00 UTC

Vote for approval (7 days)
Start Time: TBD
End Time: TBD
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.cabforum.org/pipermail/servercert-wg/attachments/20200624/f4dcb8f4/attachment-0001.html>