I’m thinking more in terms of the potential rule in the Mozilla policy. If the rule is “the CA MUST verify the domain component of the email address” then the rule potentially prohibits the scenario where the CA verifies the entire email address, not the domain component, by sending a random value to each email address and requiring the email address holder to approve issuance. I actually liked the previous requirement prohibiting delegation of email address verification, although the rule lacked clarity on what email address verification entailed. I figure that will be defined in the s/MIME working group.
Describing the actors is a good way to look at it though. Besides those three buckets of issuers, you have the RAs, the email holders, and the organization controlling the domain portion of the email address. These entities may not be the same as the CA. More often than not, the RA ends up being the organization contracting with the CA for the s/MIME services. The RAs are the risky party that I think should be restricted on what they can verify since that’s where the lack of transparency starts to come in. With the prohibition against delegation of email control eliminated, we’re again placing domain/email control responsibilities on a party that has some incentive to misuse it (to read email of a third party) without audit, technical, or policy controls that limit their authority. Because there are a lack of controls over the RAs, they become a hidden layer in the process that can issue certificates without anyone looking at how they are verifying the email address or domain name and whether these processes are equivalent to the controls found int eh BR. Similar to TLS, the unaudited party should not be the one providing or verifying acceptance of the tokens used to approve issuance. In short, I’m agreeing with the “at least” verifying the domain control portion. However, I know we verify a lot of email addresses directly with the email owner that doesn’t have control over the domain name. So the rule should be something that permits verification by the root CA of either the full email address or the domain name but at least eliminates delegation to non-audited third parties. For phrasing, “the CA MUST verify either the domain component of the email address or the entire email address using a process that is substantially similar to the process used to verify domain names as described in the Baseline Requirements”, with the understanding that we will rip out the language and replace it with the s/MIME requirements once those are complete at the CAB Forum. Jeremy From: Ryan Sleevi <r...@sleevi.com> Sent: Friday, October 4, 2019 10:56 PM To: Jeremy Rowley <jeremy.row...@digicert.com> Cc: Kathleen Wilson <kwil...@mozilla.com>; Wayne Thayer <wtha...@mozilla.com>; mozilla-dev-security-policy <mozilla-dev-security-pol...@lists.mozilla.org> Subject: Re: Policy 2.7 Proposal: Forbid Delegation of Email Validation for S/MIME Certificates Jeremy: Could you describe a bit more who the actors are? Basically, it seems that the actual issuance is going to fall into one of several buckets: 1) Root CA controls Issuing CAs key 2) Issuing CA controls its own key, but is technically constrained 3) Issuing CA controls its own key, and is not technically constrained We know #1 is covered by Root CA’s audit, and we know #3 is covered by Issuing CA’s audit, and #2 is technically constrained and thus the domain part is apriori validated. So when you say “some organizations”, I’m trying to understand which of the three cases here they fall under. If I understand correctly, the idea is that Customer Foo approaches Root CA (Case #1). Root CA knows Foo’s namespace is foo.example through prior verification, and Root CA allows Foo to issue to *@foo.example<mailto:*@foo.example>. Then Foo says “oh, hey, we have a contractor at user@bar.example<mailto:user@bar.example>, we’d like a cert for them too”. Why can’t Root CA verify themselves? Why would or should Root CA trust Foo to do it correctly? I can imagine plenty of verification protocols where Foo can be the “face” of the verification, but that it uses Root CAs APIs and systems under the hood. I‘m fairly certain DigiCert has experience doing this for their customers, such as for white label CAs. So that’s why I’m struggling to understand the use case, or the challenges, with at least requiring domain-part validation by the CA. On Fri, Oct 4, 2019 at 8:09 PM Jeremy Rowley via dev-security-policy <dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>> wrote: Will this permit either verification of the email address or the domain part? For example, some organizations may verify their entire domain space and then confirm contractors using a random value sent to the email address itself. They don't need the entire domain space in those cases, but they do need to issue certificates for a few email addresses outside of their domain control. Verification of email control using a random value seems like it affords controls that are equivalent to the challenge-response mechanisms in the BRs. -----Original Message----- From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org<mailto:dev-security-policy-boun...@lists.mozilla.org>> On Behalf Of Wayne Thayer via dev-security-policy Sent: Friday, October 4, 2019 2:38 PM To: Kathleen Wilson <kwil...@mozilla.com<mailto:kwil...@mozilla.com>> Cc: mozilla-dev-security-policy <mozilla-dev-security-pol...@lists.mozilla.org<mailto:mozilla-dev-security-pol...@lists.mozilla.org>> Subject: Re: Policy 2.7 Proposal: Forbid Delegation of Email Validation for S/MIME Certificates I'd like to revive this discussion. So far we've established that the existing "required practice" [1] is too stringent for email address validation and needs to be changed. We can do that by removing email addresses from the scope of the requirement as Kathleen proposed, or by exempting the local part of the email address as I proposed earlier: "CAs MUST NOT delegate validation of the domain name part of an email address to a 3rd party." We have a fairly detailed explanation from Ryan Hurst of why and how removing the requirement entirely is beneficial, but no one else has spoken in favor of this need. Kathleen did however point out that this requirement doesn't appear to be the result of a thorough analysis. We have Ryan Sleevi arguing that the process described by Ryan Hurst is insecure and thus a reason to forbid delegation of validation of the domain name part. Pedro Fuentes also wrote in favor of this outcome. One thing that might help to resolve this is a more detailed description of the weaknesses that are present in the process described by Ryan Hurst. If we can all agree that the process is vulnerable, then it seems that we'd have a strong argument for banning it. - Wayne [1] https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices#Delegation_of_Domain_.2F_Email_Validation_to_Third_Parties On Thu, May 23, 2019 at 12:22 PM Kathleen Wilson via dev-security-policy < dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>> wrote: > On 5/13/19 10:24 AM, Wayne Thayer wrote: > > The BRs forbid delegation of domain and IP address validation to > > third parties. However, the BRs don't forbid delegation of email > > address validation nor do they apply to S/MIME certificates. > > > > Delegation of email address validation is already addressed by > > Mozilla's Forbidden Practices [1] state: > > > > "Domain and Email validation are core requirements of the Mozilla's > > Root Store Policy and should always be incorporated into the issuing > > CA's procedures. Delegating this function to 3rd parties is not permitted." > > > > I propose that we move this statement (changing "the Mozilla's Root > > Store Policy" to "this policy") into policy section 2.2 "Validation > > Practices". > > > > This is https://github.com/mozilla/pkipolicy/issues/175 > > > > I will appreciate everyone's input on this proposal. > > > > - Wayne > > > > [1] > > > https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices#Delegat > ion_of_Domain_.2F_Email_Validation_to_Third_Parties > > > > > All, > > As the person who filed the Github issue for this, I would like to > provide some background and my opinion. > > Currently the 'Delegation of Domain / Email Validation to Third Parties' > section of the 'Forbidden Practices' page says: > "This is forbidden by the Baseline Requirements, section 1.3.2. > Domain and Email validation are core requirements of the Mozilla's > Root Store Policy and should always be incorporated into the issuing > CA's procedures. Delegating this function to 3rd parties is not permitted." > > Based on the way that section is written, it appears that domain > validation (and the BRs) was the primary consideration, and that the > Email part of it was an afterthought, or added later. Historically, my > attention has been focused on TLS certs, so it is possible that the > ramifications of adding Email validation to this section was not fully > thought through. > > I don't remember who added this email validation text or when, but I > can tell you that when I review root inclusion requests I have only > been concerned about making sure that domain validation is not being > delegated to 3rd parties. It wasn't until a representative of a CA > brought this to my attention that I realized that there has been a > difference in text on this wiki page versus the rules I have been > trying to enforce. That is when I filed the github issue. > > I propose that we can resolve this discrepancy for now by removing "/ > Email Validation" from the title of the section and removing "and Email" > from the contents of the section. > > Unless we believe there are significant security reasons to add our > own S/MIME required/forbidden practices at this time, my preference is > to wait for the CA/Browser Forum to create the S/MIME Working Group, > and for that group to identify the S/MIME baseline requirements. Then > we can add policy and required/forbidden practices based on the S/MIME > BRs provided by that group. > > I do realize that my proposal is unfair to CAs who have been > diligently following this section of this wiki page. Your diligence is > appreciated, and your contributions to this discussion will also be > appreciated. > > Thanks, > Kathleen > > > > > > > > > > > > > > > > > _______________________________________________ > dev-security-policy mailing list > dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org> > https://lists.mozilla.org/listinfo/dev-security-policy > _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org> https://lists.mozilla.org/listinfo/dev-security-policy _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org> https://lists.mozilla.org/listinfo/dev-security-policy _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
