Hi Jeremy.  I think it's unreasonable to expect the browser representatives and 
the community to always be ready to respond to incident reports within 24 
hours.  I also think that it would be a very sad state of affairs for the BRs 
and Mozilla policy to have mutually exclusive requirements.  And I also think 
that it makes no sense to prevent CAs from responding promptly to confirmed 
"security incidents" (e.g., proven key compromise, evidence from a reputable 
third party that a misissued certificate's private key is controlled by an 
attacker, etc).

In all other cases, where the CA is not able to confirm a "security incident", 
I think I could be persuaded that it's not unreasonable to require a >=24hr 
subscriber notification period prior to revocation.

________________________________
From: Jeremy Rowley <[email protected]>
Sent: 30 December 2021 18:24
To: Rob Stradling <[email protected]>; Kathleen Wilson <[email protected]>; 
[email protected] <[email protected]>
Subject: RE: Revocation Reason Codes for TLS End-Entity Certificates


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In that case, couldn’t you just include that you revoked the certificate before 
notice as part of the incident report you are already required to file for 
failing to properly do validation? In this scenario, you’re already filing an 
incident report so combining the two misses on a report doesn’t seem 
burdensome. Plus, if you’re filing incident reports promptly, then the browsers 
can provide guidance on their expectations to revoke before the 24-hour notice 
or not.  Then, the decision on when to revoke is partly a community-driven 
decision rather than something the CA is unilaterally deciding.



From: [email protected] <[email protected]> On 
Behalf Of Rob Stradling
Sent: Thursday, December 30, 2021 11:09 AM
To: Kathleen Wilson <[email protected]>; [email protected]
Subject: Re: Revocation Reason Codes for TLS End-Entity Certificates



> "When a certificate revocation is not due to key compromise and is not 
> initiated by the certificate subscriber, the CA MUST make the information 
> regarding its intent to revoke an end-entity SSL certificate available to the 
> certificate subscriber at least 24 hours before revoking the certificate."



What if the certificate revocation is due to the CA becoming aware that 
validation (particularly DCV) was not performed correctly?  In such cases, it's 
possible (perhaps even likely) that the private key is controlled only by an 
attacker; and since that private key hasn't been obtained by parties that the 
subscriber (i.e., the attacker) has not authorized, the key is not compromised.



As with key compromise, waiting 24 hours in this scenario only helps the 
attacker.



________________________________

From: [email protected]<mailto:[email protected]> 
<[email protected]<mailto:[email protected]>> on 
behalf of Kathleen Wilson <[email protected]<mailto:[email protected]>>
Sent: 30 December 2021 17:44
To: [email protected]<mailto:[email protected]> 
<[email protected]<mailto:[email protected]>>
Subject: Re: Revocation Reason Codes for TLS End-Entity Certificates



CAUTION: This email originated from outside of the organization. Do not click 
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Many thanks to all of you for your continued input.



I have updated the first sentence of the second paragraph of the 
draft<https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdocs.google.com%2Fdocument%2Fd%2F1ESakR4MiwyENyuLefyH2wG8rYbtnmG1xeSYvDNpS-EI%2Fedit%3Fusp%3Dsharing&data=04%7C01%7Crob%40sectigo.com%7Cd10f017744394c3804f608d9cbc19958%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C637764854642365017%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=JUlKuiG5Nn5zTTslhAaHaAJ8zxsywUcTO%2FoQMXcto90%3D&reserved=0>
 to the following, and will continue to appreciate your help with the wording. 
My intent is to provide some protection to the website operator so that a CA 
cannot revoke their certificate for non-critical reasons without letting them 
know and take action first. The responsibility may be on the website operator 
to have automation to check for that information, as opposed to sending 
notifications via email. So I will continue to appreciate your help with the 
wording.



"When a certificate revocation is not due to key compromise and is not 
initiated by the certificate subscriber, the CA MUST make the information 
regarding its intent to revoke an end-entity SSL certificate available to the 
certificate subscriber at least 24 hours before revoking the certificate."





I am particularly interested in having more discussion about the following from 
Rob:



On Thursday, December 30, 2021 at 8:37:07 AM UTC-8 
[email protected]<mailto:[email protected]> wrote:

I can understand why the keyCompromise and cACompromise reason codes are of 
interest, but I'm struggling to see why Mozilla might be interested in 
differentiating between privilegeWithdrawn, cessationOfOperation, and 
superseded.  Why are any of these 3 reason codes more useful than having no 
reason code at all?  What use cases would be enabled if CAs were to use these 3 
reason codes as you propose?



FWIW, at the moment my counter-proposal would be roughly along these lines (for 
leaf certificate revocations):

  - CAs MUST use keyCompromise for (and only for) proven or suspected key 
compromise.

  - CAs MUST revoke immediately in the case of proven key compromise.

  - CAs SHOULD NOT use other reason codes.

  - Beyond that, follow the BRs.





How do you all think that browsers should enforce end-entity TLS certificate 
revocations?

e.g.

Should ALL end-entity TLS certificate revocations be enforced via 
non-over-rideable errors?

Or should the user be able to continue past the error to the website when the 
revocation is for something other than key compromise?

Should a non-over-rideable error be presented for end-entity TLS certificates 
that are revoked for privilegeWithdrawn?

Should a non-over-rideable error be presented for end-entity TLS certificates 
that are revoked for cessationOfOperation?

Should a non-over-rideable error be presented for end-entity TLS certificates 
that are revoked for superseded?



We all know that if user gets a non-over-rideable error in one browser they 
will try again with another browser, so enforcing any revocations in only one 
browser will not be very effective in protecting the user. So I am looking for 
a solution that may be more broad than Firefox, with the hopes that other 
browsers will be able to eventually use the revocation reasons for end-entity 
TLS certificates too. I am under the impression that other browsers will not 
enforce ALL end-entity TLS certificate revocations with hard fail, and that the 
rules about the use of certain revocation codes must be in place and in use 
before they will consider automatically enforcing via hard fail any end-entity 
TLS certificate revocations.



Thanks,

Kathleen









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