[cabf_validation] Revision to OU requirements

Thu Sep 24 08:38:19 MST 2020

Hi Ryan,

my point is, that for sure it’s possible to have different setups for different purposes. However, our experience (e.g. on client and s/mime certificates, e.g. especially for the german energy sector) is, that different setups for different purposes make it harder for CA to handle (and offer) as well as for customers as missing interoperability in usage. Solutions, which are usable for multiple purposes (but also require similar design and requirements) are very well welcome. As for such, fundamental changes like OU removal may disrupt such interoperability.

Regards
Christian

Von: Ryan Sleevi <sleevi at google.com>
Datum: Donnerstag, 24. September 2020 um 16:00
An: Christian Heutger <ch at psw.net>
Cc: CA/Browser Forum Validation SC List <validation at cabforum.org>
Betreff: Re: [cabf_validation] Revision to OU requirements

Hi Christian,

I'm not sure I understand your point here. The CA/Browser Forum is a discussion forum for browsers and CAs to discuss product requirements for browser products. While I agree that PKI technologies are used in a wide variety of use cases, proving how general purpose the technology is, there's no requirement that they all use the same CA infrastructure. Indeed, as the industry has shown consistently, both in terms of standards evolution and in response to security incidents, there are ample harms from using the "same" certificate hierarchy. That doesn't mean a single organization can't operate multiple hierarchies, but we should be careful to not mistake PKI hierarchies as general purpose, because they are not.

In this model, it helps to think of PKI like JSON or XML: a general purpose technology for expressing attributes, but specific uses of it (e.g. specific APIs or service endpoints) will define their own requirements on how that general technology is used. Much like it would be strange to think of an API for listing, say, shopping products, use the same structure and format as an API for managing smart meters, we can substitute "API" for "PKI" and get the same conceptual clarity about why they are fundamentally different.

As it relates to the question I asked of Michelle, which you're replying to here, it appears the relevant standards document is WEQ-012, developed by NAESB, and recognized by FERC. In that case, it would appear there is limited to no risk of the removal of OU creating incompatibility, because it appears the specification for the NAESB PKI within WEQ-012 is already incompatible with the specification for browser PKIs within browser root store requirements and the Baseline Requirements. Of course, I'm certainly hoping Michelle can share more details, such as a readily attainable public version of the most recent version, to facilitate further discussion.

On Thu, Sep 24, 2020 at 5:26 AM Christian Heutger <ch at psw.net<mailto:ch at psw.net>> wrote:
Hi,

SSL/TLS certificate usage is much wider than only for Web Sites, primary they are server certificates. Similar to client certificates, which may be S/MIME certificates, user certificates, signing certificates on machines, clients or gateways. The view here seems sometimes a bit to reduced, but has larger impact as sometimes recognized.

Regards,
Christian

Von: Validation <validation-bounces at cabforum.org<mailto:validation-bounces at cabforum.org>> im Auftrag von Ryan Sleevi via Validation <validation at cabforum.org<mailto:validation at cabforum.org>>
Antworten an: Ryan Sleevi <sleevi at google.com<mailto:sleevi at google.com>>, CA/Browser Forum Validation SC List <validation at cabforum.org<mailto:validation at cabforum.org>>
Datum: Donnerstag, 24. September 2020 um 00:11
An: Michelle Coon <Michelle.Coon at oati.net<mailto:Michelle.Coon at oati.net>>, CA/Browser Forum Validation SC List <validation at cabforum.org<mailto:validation at cabforum.org>>
Betreff: Re: [cabf_validation] Revision to OU requirements

Thanks Michelle,

This is really useful! However, it's not clear to me why the wholesale electric industry is using browser-based certificates. The discussion here would only be regarding those used as part of browser/OS, and surely these devices aren't using the same trust anchors, given the risks, right? Certainly, using a dedicated trust anchor for different compliance regimes has long been understood as good practice, at least within the Forum, as we saw first-hand with 1024-bit RSA and SHA-1.

Given the size and depth of this information, could you perhaps provide a more specific reference? Looking through FERC 888, 889, and 2222, I don't see any specific references to organizationalUnit. Perhaps I'm overlooking something, however?

On Wed, Sep 23, 2020 at 3:59 PM Michelle Coon via Validation <validation at cabforum.org<mailto:validation at cabforum.org>> wrote:
OATI has the following comments regarding the OU field discussion:
The wholesale electric industry currently uses the optional OU field in the certificate string of client certificates to identify a specific organization unit having authority to conduct business transactions as allowed under regulatory requirements promulgated by the Federal Energy Regulatory Commission (FERC). In FERC Orders 888 and 889, utilities were required to isolate business units for purposes of sharing transmission grid information. Transmission and wholesale energy trading business units in all major U.S. grid interconnections, Western, Eastern, and ERCOT, are required to be broken up into separate business units for different activities. Different units must be completely "brick walled" from each other, and operate as different entities even though they are still technically sub units of the same company. For more than 20 years, OU field has been and is currently used by energy industry entities as an integrated business process to clearly and distinctly identify the specific organization unit associated with discrete certificates in compliance of FERC Orders 888 and 889. Additionally, with the recent FERC Order 2222, the use of the optional OU field in the certificate string may be expanded as a business practice to the distribution/retail level of power entities as integrated into energy markets of North America.
Removal of the optional OU field in the certificate string would cause disruption of current business practice in the energy industry of North America. Specifically, removal of the optional OU field would prevent energy industry entities from clearly and distinctly identifying the specific organization unit associated with discrete certificates, thereby compromising their compliance with U.S. federal regulatory mandates. Additionally, it would require energy industry entities to modify their current business processes, requiring time, staff, and resources.
The OU field in the certificate string is optional and should remain optional, to accommodate all organizations-those that use the optional OU field as part of their established business processes, as well as those organizations that do not use the optional OU field.

Michelle Coon
Associate Director, Compliance
Phone: 763.201.2000<tel:(763)%20201-2000>
Fax: 763.201.5333<tel:(763)%20201-5333>
Open Access Technology International, Inc.
3660 Technology Drive NE, Minneapolis, MN 55418

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-----Original Message-----
From: Validation [mailto:validation-bounces at cabforum.org<mailto:validation-bounces at cabforum.org>] On Behalf Of Kurt Roeckx via Validation
Sent: Monday, September 21, 2020 3:47 PM
To: Ryan Sleevi <sleevi at google.com<mailto:sleevi at google.com>>; CA/Browser Forum Validation SC List <validation at cabforum.org<mailto:validation at cabforum.org>>
Subject: Re: [cabf_validation] Revision to OU requirements

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On Mon, Sep 21, 2020 at 02:01:20PM -0400, Ryan Sleevi via Validation wrote:
> Can you clarify: Was this at the request of BCSS (the "server", in
> their
> parlance) or in the use of TLS certificates as client-auth certificates?
>
> This appears to be detailing a very specific mutual-TLS authentication
> flow, and it's unclear whether or not a browser-used CA is essential
> for this.

Reading the document, it says that the KSZ/BCSS/CBSS has 3 certificates (TLS server, TLS client, TLS client to sign documents), and depending on the communications, one of the 3 is used. Clients wishing to authenticate them should get the certificates. Clients should also send their own certificate to KSZ/BCSS/CBSS.

Kurt

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