On 22/04/18 21:04, Eric Mill via dev-security-policy wrote:
On Fri, Apr 20, 2018 at 9:30 AM, Tim Shirley via dev-security-policy <
[email protected]> wrote:

First of all, it's important to distinguish between the BR r
But even if you accept my premise there, then you have to ask "in what
timezone?"  March 1 00:00:00 2018 GMT in North America is February 28.  So
I could see someone making the argument that issuance at that moment in
time is fine if the CA is in North America but it's mis-issuance if the CA
is in Europe, since the requirements don't state that the measurement is
UTC.  This is why I'm not a fan of such precise enforcements of
date-related compliance.  There are a lot of different ways to interpret
dates/times, but none of the readings materially change the net effect of
the rule.  That is, all readings change the max validity period to ~825
days (which itself is subject to debate as to its precise meaning in terms
of seconds) within a day or two of each other.  So, enforcing the date as
Mar 1 as opposed to Mar 2 doesn't seem to add a lot of value and leads to
confusion like this.

I'm just going to double down on Matt's comment that the problem here
doesn't seem to be in strictness of enforcement, but rather CAs leaving
themselves no buffer zone.

The problem here, IMHO, is that the BR requirement was poorly written.

Whatever business advantage there is of giving
customers that one last day to get 3-year certs, seems likely not as
valuable as the certainty of avoiding giving those customers errors when
the certs are used in major browsers.

The certainty? Hindsight is a wonderful thing. When I wrote Comodo CA's code to enforce the "after 1 March 2018" rule, this "certainty" did no occur to me. I simply read the BR requirement and then implemented code to enforce it.

-- Eric



On 4/19/18, 10:10 PM, "dev-security-policy on behalf of Simone Carletti
via dev-security-policy" <dev-security-policy-bounces+tshirley=
[email protected] on behalf of dev-security-policy@lists.
mozilla.org> wrote:

     Hello,

     I'm investigating an issue on behalf of a customer. Our customer
requested a multi-year certificate that was issued on March 1st by Comodo.

     Here's the certificate:
     https://crt.sh?id=354042595

             Validity
                 Not Before: Mar  1 00:00:00 2018 GMT
                 Not After : May 29 23:59:59 2021 GMT

     The certificate is currently considered invalid at least by Google
Chrome.

     It's my understanding that Google Chrome uses a >= comparison, which
effectively means certificates issued on March 1st are already subject to
Ballot 193.

     However, it looks like the interpretation of Comodo of Ballot 193 here
is based on a > comparison, since the certificate was issued with a 3y
validity.

     BR 6.3.2 says:

     > Subscriber Certificates issued after 1 March 2018 MUST have a
Validity Period no greater than 825 days.
     > Subscriber Certificates issued after 1 July 2016 but prior to 1
March 2018 MUST have a Validity Period no greater than 39 months.

     I'd appreciate some hints about whether a certificate issued on March
1st should be considered subject to Ballot 193 or not.

     Best,
     -- Simone

--
Rob Stradling
Senior Research & Development Scientist
Email: [email protected]
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