Hi Arno,

Tools like https://github.com/alex/ct-tools or
https://github.com/grahamedgecombe/ct-submit can be used to manually submit
specific certificates to CT logs.

Alex

On Thu, Aug 17, 2017 at 9:07 AM, Arno Fiedler via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> Am Montag, 14. August 2017 18:44:59 UTC+2 schrieb Jonathan Rudenberg:
> > Hi Arno and Martin,
> >
> > > On Aug 14, 2017, at 11:44, Arno Fiedler <arno.fied...@outlook.com>
> wrote:
> > >
> > > Dear Forum,
> > >
> > > since the 07-07-2017, all new issued D-TRUST TLS-Certificates have at
> least 64 bits of entropy in the serial number.
> > >
> > > Since 01-12-2016 D-TRUST TLS certificates requested via our enterprise
> platform have a serial number which includes at least 64 bits of entropy.
> We informed the CA-Program Manager about the 3 Month delay in moving the
> entropy from the "DNqualifier” to the “SerialNumber” via eMail on 27-10-16.
> >
> > Does this mean that you knew you would not be complying with Ballot 164
> / BRs 1.3.7 by the effective date of 2016-09-30? When did you realize this?
> Did you receive permission for this non-compliance from the relevant
> Application Software Suppliers, including Mozilla?
> Answer:
> We realized that there were problems with the implementation of Ballot 164
> in September 2016 and we informed the Rootstore/Browser Provider via email
> on 2016-10-27 that we  would be delayed until December 2016.
> We believed ourselves to be compliant with Ballot 164 from 2016-12-01 when
> we implemented it into our enterprise platform. However, on 2017-08-07, we
> received knowledge about the case.
>
> > > Between 2012 and 06-07-2017 we still produced a smaller number of
> certificates using our retail platform with additional entropy in the
> “DNqualifier” field instead of the serial number field, because our
> certified third party software was not able to handle long serial numbers
> earlier.  We defined this issue as minor nonconformity, because the
> requirement for entropy in the certificate was fulfilled.
> >
> > What other issues have you defined as a "minor nonconformity"?
> Answer:
> We didn´t detect any other minor nonconformity. In general we work with an
> accreditation scheme based on ISO 27 and EN 319 403 to implement the
> requirements from Root-Policies, CA/B-Forum Guidelines, eIDAS-Regulation
> and ETSI Policies, there are defined audit procedures to recognize, control
> and remediate nonconformities under the supervision of the certification
> audit body
> >
> > > On 20-07-17 Mozilla asked D-TRUST for clarification, due to the
> holiday period this message reached us on 07-08-17, AF answered on 08-08-17
> and 10-08-17: “the certificate has 64 bits of entropy in the "DNqualifier"
> field instead of the serial number field. Since 2012 we used this way of
> adding random bits to certificates to mitigate preimage attacks. From a
> security perspective the amount of Entropy in the certificate should be
> reasonable”.
> > >
> > > On 10-08-2017 we got the information, that we issued in the Individual
> Certificate Registration process a certificate with less entropy than 64
> bit, Jonathan reported “The DNqualifier appears to have a 33-bit number,
> not a 64-bit number”.
> > >
> > > On the 11-08-2017 we defined this case as a major issue, because our
> internal examinations confirmed, that just using numeric characters causes
> entropy less than 64 bit.
> > >
> > > The review with our tool “PKI-watcher” gave the following result of
> effected certificates:
> > >     D-TRUST SSL Class 3 CA 1 2009 (607)
> > >     D-TRUST SSL Class 3 CA 1 EV 2009 (63)
> >
> > To provide transparency, can you please add all of these certificates to
> at least one CT log and post the serial numbers, certificate fingerprints,
> or crt.sh IDs?
> Answer:
> We have implemented the CT logs into our EV production process and are
> currently unaware about how to manually export specific certificates to a
> log; we will publish the affected certificate serial numbers immediately
> via *.csv. Please advise us about the receiver.
> A new certificate – instead of “www.lbv-gis.brandenburg.de/lbvagszit” –
> has been issued, the old one is revoked.
> Arno
>
> >
> > Jonathan
>
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> dev-security-policy@lists.mozilla.org
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>
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