All,
For the sake of uniformity, I think we're willing to synchronize with the
Chrome 5-year limit on key generation.  I'll make that change for the next
version announced.
Ben

On Fri, Sep 9, 2022 at 6:56 AM Ryan Dickson <[email protected]> wrote:

> Hi all,
>
> TL;DR: We’re willing to consider moving the key freshness requirement
> from 5 years to 3 in a future policy update. Reducing the key-freshness
> requirement was always part of our long-term strategy.
>
> Dimitris’ use-case description is what we were hoping to accommodate.
> We’ve seen key generation audit reports where over 50 keys were generated
> at once, with the specific acknowledgment that the keys were created for
> future use (i.e., “parked”). Even a year after generation, we do not
> observe the corresponding public key included in publicly-available
> certificates (or, by extension, public root program application queues).
> We’ve even observed an audit report that included over 150 keys. To be
> clear, this is not a commentary on this practice; I’m simply highlighting
> the existence of the use case described by Dimitris.
>
> In any event, our long-term plan before Ben’s post was to reduce the
> “key-freshness” requirement introduced in our V1.1 policy update. One of
> the reasons we did not initially require a shorter key-freshness period was
> because we recognize the effort, cost, and time commitment required by CAs
> to apply to root programs - and ultimately become “publicly trusted.”
> Imposing a more strict key-freshness requirement when one did not
> previously exist in any public root program policy would have resulted in
> additional churn by CA owners observed in other public root program
> application queues without guaranteed security value. So, ultimately, we
> chose five years to balance practical security goals (described below) and
> the planned launch of our program, with a longer-term goal of eventually
> reducing this period after better understanding the impact on applicants.
>
> We value the use of “fresh” key material because:
>
>    -
>
>    When coupled with our future proposed
>    
> <https://www.chromium.org/Home/chromium-security/root-ca-policy/moving-forward-together/#encouraging-modern-infrastructures-and-agility>
>    CA term limit, it establishes a ceiling for the maximum time a key that has
>    been unknowingly compromised could impact the security of Chrome’s users.
>    -
>
>    The Baseline Requirements and audit schemes permitted therein have
>    been continuously improving since their inception. Aligning with modern
>    requirements, practices, and audit frameworks is the only way of benefiting
>    from that improvement. For example, WebTrust’s lifecycle management audit
>    as we know it today wasn’t established until 2019
>    
> <https://cabforum.org/wp-content/uploads/22.-Webtrust-CABF-update-June-13.pdf>
>    .
>    -
>
>    Similar to the Baseline Requirements and corresponding audit schemes,
>    the same continuous improvement is true for the software libraries and
>    systems that generate and protect key material.
>    -
>
>    As above, it allows the ecosystem to realize the benefits of
>    continuous improvement efforts made by CAs regarding the ongoing management
>    of key generation scripts and ceremonies.
>    -
>
>    It promotes agility.
>    -
>
>    Being well-versed and well-rehearsed in performing key generation
>    ceremonies will prepare us better for the future (i.e., preparing for a
>    “post-quantum” world where we may quickly need to instantiate new CAs).
>
>
> Related to this issue, in a future policy update, we may clarify our
> expectations regarding how “parked keys” must be audited and represented in
> audit statements, similar to the structured reporting format required for
> CA certificates (see Section 8.6 of the BRs).
>
> Thanks, and please let me know if there are any questions!
>
> - Ryan
>
> [on behalf of the Chrome Root Program]
>
>
> On Thu, Sep 8, 2022 at 3:13 AM Dimitris Zacharopoulos <[email protected]>
> wrote:
>
>>
>>
>> On 8/9/2022 2:02 π.μ., Ben Wilson wrote:
>>
>> Hi Dimitris,
>> Thanks. I don't know why Chrome chose five years because I can't think of
>> a scenario where a CA operator would take 4-5 years to submit their root CA
>> for inclusion in the trust store. Whereas, three years seemed more
>> reasonable and manageable.
>>
>>
>> Without being 100% certain, I believe there is a use case where a CA
>> performs a key generation ceremony witnessed by an external Qualified
>> auditor, then "park" those keys making sure they are covered in annual
>> audits by providing "key protection" audit reports for the keys not
>> associated with Root CAs. This has been presented in CABF F2F meetings
>> several times. I assume that a CA with "parked keys" could pick some of
>> those keys up 4 years from creation and create a Root CA(s) to be included
>> in Root stores without needing to perform another (costly?) keygen
>> witnessed by an external auditor.
>>
>> Either way, I'm more concerned about the deviation from the Chrome Root
>> Store Policy than the decision of 3 or 5 years :) Hopefully the two
>> programs can align (either Chrome change to 3 years or Mozilla change to 5).
>>
>>
>> Dimitris.
>>
>> Ben
>>
>> On Tue, Aug 30, 2022 at 12:39 PM Dimitris Zacharopoulos <[email protected]>
>> wrote:
>>
>>>
>>>
>>> On 16/8/2022 12:28 π.μ., Ben Wilson wrote:
>>>
>>> Addition to:  Section 7.1 Inclusions
>>>
>>> CA key material MUST be generated within the three (3) years that
>>> precede the submission of a CA inclusion request. The date of CA key
>>> material generation shall be determined by reference to the auditor’s key
>>> generation ceremony report.
>>>
>>>
>>> Why 3 years instead of 5? What are the security benefits of a key being
>>> generated 3 vs 5 years ago? The Chrome Root Program Policy states that it
>>> will accept keys generated 5 years ago so perhaps there is no significant
>>> reason to justify this policy divergence.
>>>
>>>
>>> Thanks,
>>> Dimitris.
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>>>
>>
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>

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