Hi Youfu,

> This appears to remove the feasibility of DNS-based monitoring
approaches that rely on polling a fixed namespace.

I'm not sure that I understand the problem you are presenting. According to
the draft, the account-specific namespaces look like this:

  _ujmmovf2vn55tgye._acme-challenge.example.org

I am not a deep expert in DNS, but can't you still monitor _*._
acmechallenge.example.org, the same way you currently monitor
_acmechallenge? Or is it not feasible in most DNS setups to query all
subdomains, and you can only query if you know the exact subdomain to query
for? I do think you are raising a good point that the authors should
address in the Security Considerations section.



Having reviewed the document, I have a few comments of my own for the
authors;q

Section 3.2 contains this example:
_ujmmovf2vn55tgye._acme-challenge.example.org 300 IN TXT
"LoqXcYV8...jxAjEuX0.9jg46WB3...fm21mqTI"


I think it well-explained where the "_ujmmovf2vn55tgye" comes from, but
where does the "LoqXcYV8...jxAjEuX0.9jg46WB3...fm21mqTI" come from? Is that
supposed to be the token from the challenge? If so, you should add a bullet
explaining this, and align that to the example in 3.1 which currently has
"token": "ODE4OWY4NTktYjhmYS00YmY1LTk5MDgtZTFjYTZmNjZlYTUx". I also don't
see this well explained in 3.3.


You mention in Sec Cons that 10 bytes of the SHA256 hash should be enough
to handle non-malicious collisions. You should do the math and list out the
probability that two Account URLs collide, and say what an ACME client
should do if a collision happens -- I suppose the default is that it
actually doesn't know that there has been a collision since this looks like
the existing DNS record was from a previous run of it, and it just
over-write the value. But I think you should include this somewhere in the
document as an operational pitfall that operators should watch out for --
it will manifest as there being one less ACME DNS record than they are
expecting to see.

On Sun, 29 Mar 2026 at 01:51, Youfu Zhang <[email protected]> wrote:

> Hi all,
>
> I would like to raise a potential operational/security consideration
> around DNS-ACCOUNT-01.
>
> Prior to DNS-ACCOUNT-01, ACME DNS-based validation methods (e.g.,
> DNS-01, DNS-PERSIST-01) relied on well-known, predictable labels such
> as _acme-challenge.<domain>. This enabled domain owners or third
> parties to monitor those names for unexpected TXT records as a weak
> signal of ongoing or potentially unauthorized validation activity.
>
> With DNS-ACCOUNT-01, the validation name incorporates an
> account-derived label. As a result, the effective validation namespace
> becomes unpredictable to observers who do not already know the ACME
> account URI.
>
> This appears to remove the feasibility of DNS-based monitoring
> approaches that rely on polling a fixed namespace. In effect,
> DNS-ACCOUNT-01 replaces a shared, predictable monitoring surface with
> per-account isolation.
>
> A few questions for the WG:
> - Is this reduction in a predictable DNS monitoring surface an
> intentional trade-off of DNS-ACCOUNT-01?
> - Has the WG considered whether this changes the detectability of
> unauthorized validation activity in environments where DNSSEC is not
> deployed (e.g., where DNS responses may be forged/modified on-path)?
> - Would it be useful to document this explicitly in the Security
> Considerations section, so operators are aware that DNS-based
> monitoring techniques targeting _acme-challenge no longer generalize?
>
> To be clear, I understand that Certificate Transparency is the primary
> mechanism for detecting misissuance. This question is specifically
> about whether DNS-ACCOUNT-01 removes a secondary (albeit weaker)
> monitoring signal that some operators may currently rely on.
>
> Thanks,
> Youfu Zhang
>
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