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mind that MDSP has a moderation queue for new members. If the report is to 
be sent to the mailing list today, then please make sure to use an account 
that has been pre-approved, or otherwise submit it early enough that a 
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On Wednesday, May 15, 2024 at 4:06:49 PM UTC+1 Amir Omidi (aaomidi) wrote:

> I wanted to also add that I'd like Entrust to address why they don't stop 
> certificate issuances when they find out they're misissuing certificates?
>
> As part of my series on Entrust 
> <https://webpki.substack.com/t/entrust-considered-harmful>. In Part 2 
> <https://webpki.substack.com/p/entrust-considered-harmful-part-2> I found 
> a concerning issue from Entrust that went unnoticed at the time, which 
> shows a pattern of gross-negligence when it comes to incident response: 
> Entrust: 
> SHA-256 hash algorithm used with ECC P-384 key 
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1648472>
>
> In this incident, Entrust discovers that they're misissuing certificates 
> on 2020-06-17. Despite finding out about this incident, they continue to 
> misissue certificates all the way till 2020-06-24: 
> https://crt.sh/?id=2998515551&opt=zlint 
>
> There have been a couple of examples of Entrust making this decision in 
> the past, such as: Entrust: Printable String Constraint Failure 
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1635096>. Similar to the 
> previous incident, they did not disable issuance on their systems that was 
> capable of misissuing certificates (emphasis mine):
> >      Whether your CA has stopped, or has not yet stopped, issuing 
> certificates with the problem. A statement that you have will be considered 
> a pledge to the community; a statement that you have not requires an 
> explanation. 
>
>         The CA software has a bug which encodes quotation marks in the 
> organization field using PrintableString instead of UTF8String. *This 
> software has not been fixed at this time.*
>
> And more recently, we saw this behavior in the start of this saga: Entrust: 
> EV TLS Certificate cPSuri missing 
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1883843#c4> 
>
> On Saturday, May 11, 2024 at 6:37:52 PM UTC-4 Wayne wrote:
>
>> I can't speak for everyone but in an issue of public trust asking for 
>> private feedback and concerns is not helping matters.
>>
>> One of the prevalent topics that have came up in these issues is shorter 
>> certificate lifespans, certificate automation and how Entrust are working 
>> very hard with their customers. I'm very curious if Entrust can quantify 
>> this in any way?
>>
>> Taking a step back and just looking at their public statements regarding 
>> lifespans, automation and ACME should give us an idea of their internal 
>> viewpoint and how this topic is presented to customers. Outside of the 
>> first issue I won't be quoting bugzilla, it's there solely to provide 
>> context as I can't see an earlier point that automation was promised.
>>
>> Let's dive in, sources all provided if there are any questions about the 
>> rough transcript or context.
>>
>> *1: 2023-03-27: Entrust: Delayed Revocation for EV TLS Certificate 
>> incorrect jurisdiction*
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753#c8
>> *---*
>> Late revocations are base primarily by Subscribers which have not 
>> implemented automation. We have increased our efforts to extend 
>> implementation of ACME. We are also considering implementing the ACME 
>> Renewal Information (ARI) Extension, which allow the certificate to be 
>> automatically renewed before the revocation date.
>>
>> In the shorter term, we will provide Subscribers with automated reminders 
>> on the revocation date for miss-issued certificates. We will plan to allow 
>> short extensions, based on the severity of the miss-issuance.
>> *---*
>>
>>
>>
>> *2: 2023-04-21: Google’s 90 day proposal for TLS certificates*
>>
>> https://www.entrust.com/blog/2023/04/googles-90-day-proposal-for-tls-certificates/
>> *---*
>> Even if CAs and other browsers don’t share Google’s objectives, there is 
>> a chance that Google could unilaterally make this change in its root 
>> program and force the entire industry in this direction in a time of their 
>> choosing. We hope that browsers will not make this decision unilaterally, 
>> but instead allow the decision to be made with broad industry and website 
>> owner consensus.
>>
>> Another issue is that Google has presented no public research or factual 
>> data showing that such a change to the ecosystem is necessary or useful in 
>> many use cases. We believe there will be much discussion before a 90-day 
>> ballot will pass at the CABF as several CAs have indicated that a 
>> requirement for 90-day certificates might have far-reaching implications. 
>> There have also been several EU governmental bodies concerned over the 
>> market and competitive implications of Google’s proposal and the impact on 
>> eIDAS Qualified Website Authentication Certificate objectives, which are 
>> now being reasserted in the EU’s update of its eIDAS legislation.
>>
>> Entrust does not believe that a maximum 90-day limit for TLS certificate 
>> lifetimes is the only method to drive automation and the deployment of 
>> ACME. Additionally, Entrust doesn’t believe that ACME is the only method 
>> for automation, or that it would be accepted by some of the most complex 
>> subscriber secure server deployments. Rather, we believe subscribers should 
>> be encouraged to deploy automation, but do not need to be discouraged by 
>> the cost and complexity of certificates with 90-day maximum validity.
>>
>> While Entrust is not currently in favor of a mandatory 90-day certificate 
>> limit, we have no objection to 90-day certificates if that is what a 
>> website wants to use. We are always working to improve or extend its 
>> validation, issuance, and management processes, including greater use of 
>> automation through integrations with certificate lifecycle management (CLM) 
>> solutions such as Entrust Certificate Hub, AppViewX, Venafi, and 
>> ServiceNow, as well as automation through ACME v2, CMP, SCEP, and other new 
>> methods.
>>
>> We understand that this Google proposal may be causing our customers 
>> considerable concern. In accordance with Google’s instructions on its 
>> Chrome Root Program Policy, we encourage customers to direct any questions 
>> or input regarding the Google proposal to [email protected]; 
>> please feel free to share a copy with us at [email protected].
>> *---*
>>
>>
>>
>> *3: 2023-07-26: Entrust Cybersecurity Institute Explains: 90-day TLS/SSL 
>> Certificate Lifecycle*
>> https://www.youtube.com/watch?v=GcKunPD5SRw
>> *---*
>> 0:41-1:48
>> Today we're using certificates that are generally valid for about a year. 
>> Technically, according to the requirements, we can go to 398 days to give 
>> you a bit of room so that you can have one day of the year at which you 
>> renew your certificates. That is something that is easy to remember, 
>> scheduling your agenda as a yearly renewal of those certificates when they 
>> need to happen.
>>
>> When they're moving to shorter-lived certificates, such as the proposed 
>> 90 days, this means that you need to do this now four times a year in a 
>> window of 90 days. 
>>
>> Moving to 90-day certificates means that you're practically going to 
>> renew your certificates probably every 60 days. Meaning that in the end, 
>> you have to replace your certificates four to six times a year, depending 
>> on what window you allow to renew that certificate.
>>
>> 90-day certificates will have a few benefits. So one is that they will 
>> drive automation.
>>
>>
>> 2:51-3:30
>> That doesn't [mean to] say that there's no problems and that 90-day 
>> certificates are actually going to solve this. Crypto agility is important, 
>> but that means more than just automating your certificate lifecycle.
>>
>> For example, if the CA would give you an indication through the automated 
>> system that your certificate must be replaced, how does currently the CA 
>> know that your system is capable of running a certain algorithm? Have you 
>> updated your libraries?
>>
>> So we still have a long step ahead of us really to make that crypto 
>> agility a reality.
>>
>> 4:41-end
>>
>> We're working with the Internet Engineering Task Force, where Anthos(?) 
>> created a proposal for a sort of auto-discovery based on the most used 
>> automation, the ACME Auto Certificate Management Environment.
>>
>> And that would help our customers actually to simplify this mechanism of 
>> renewing certificates in different platforms with different systems, 
>> without having to reconfigure every individual system to work with the 
>> certificate authority and the type of certificates they're dealing with. 
>> Together with[sic] very important is one of the risks of automation, is 
>> that you're not doing it as a human. 
>>
>> If you do a process, if you follow a step-by-step process that is defined 
>> and tested, then you know the outcome, because you're following the steps. 
>> But in automation, something might go wrong. And how do you know? You need 
>> to make sure that systems are notifying you as someone is watching the 
>> notifications.
>>
>> That's also why in this similar proposal, we've included the mechanism of 
>> backup configuration. So if one process would fail, there is another 
>> process that can be followed. But other things are still in development. 
>> And we will see how that turns out. But the ecosystem seems to be 
>> supporting it.
>> *---*
>>
>>
>>
>> *4: 2023-07-26: Entrust Cybersecurity Institute Explains: Zero Trust and 
>> TLS/SSL Certificate Management*
>> https://www.youtube.com/watch?v=nd0QCvu2F_E
>> *---*
>> 1:20-2:18
>>
>> Well, first I would say we need to adopt automation. But then at the same 
>> point, I would point them at the risk of automation. Where processes by 
>> humans are easily manageable and can have multiple steps to ensure they 
>> flow correctly. Without automation, this could be more challenging.
>>
>> For example, if you implement automation for your TLS certificates, this 
>> means that you need to have a credential for your certificate authority. 
>> You need to also have a credential, for example, for your domain name 
>> provider, your DNS system. And that's all needed to prove domain control 
>> and to make sure that a certificate with the right identity is issued for 
>> your endpoints.
>>
>> But what if these credentials get compromised? Look at the DNS system.
>> *---*
>>
>>
>>
>> *5: 2023-08-14: Short-lived Certificates finally approved*
>>
>> https://www.entrust.com/blog/2023/08/short-lived-certificates-finally-approved/
>> *---*
>> After more than 10 years, short-lived TLS certificates are finally 
>> permitted by the browsers based on CA/Browser Forum ballot SC-063. Gerv 
>> Markham started a short-lived certs discussion in 2014, where he advised he 
>> was reviewing the 2012 CA/Browser Forum discussion on the topic. He advised 
>> that short-lived certificates was a plank of the Mozilla revocation 
>> strategy. There was also a paper prepared in 2012 called Towards 
>> Short-Lived Certificates. The paper stated OCSP is as good as dead, so the 
>> CAs should issue certificates with a very short lifetime. I suppose no one 
>> thought it would take so much time.
>>
>> Short-lived certificates are designed to help address a certificate 
>> revocation issue. Back in 2012, Adam Langley discussed the seat-belt issue, 
>> where it works fine, but snaps when you crash. This was based on the fact 
>> the browser implements soft-fail revocation checks where the CRL or OCSP 
>> response is ignored.
>> *---*
>>
>>
>>
>> *6: 2024-03-26: The Path to 90-Day Certificate Validity: Challenges 
>> Facing Organizations*
>>
>> https://www.entrust.com/blog/2024/03/the-path-to-90-day-certificate-validity-challenges-facing-organizations/
>> *---*
>> Certificate lifespan is getting shorter
>>
>> Over the years the cybersecurity industry has undergone notable 
>> transformations requiring organizations to implement new best-practice 
>> standards, often at a short notice.
>>
>> In 2020, Apple unilaterally opted for shorter TLS certificate durations, 
>> reducing them from three years to 398 days, thereby increasing the burden 
>> on certificate management. Subsequently, Apple introduced shorter lifespans 
>> for S/MIME certificates at the start of 2022. In the past year, both code 
>> signing and S/MIME users faced additional alterations, while Google 
>> proposed transitioning to 90-day certificates, a subject we have explored 
>> in our latest webinar. Anticipating further changes, particularly with the 
>> rise of artificial intelligence (AI) and the looming risk of post-quantum 
>> (PQ) computing, organizations must enhance their agility.
>>
>> Today, TLS/SSL certificates are typically valid for about a year, 
>> according to the Certification Authority Browser (CA/B) Forum requirements. 
>> This yearly renewal cycle is convenient for organizations to manage and 
>> schedule. However, transitioning to shorter-lived certificates, like the 
>> proposed 90-day validity period, will require more frequent renewal 
>> efforts. With 90-day validity, organizations will need to renew 
>> certificates four times every 12 months within that timeframe. In practice, 
>> due to the need for buffer time, certificates may need to be renewed every 
>> 60 days. Ultimately, this change could lead to replacing certificates more 
>> than six times every 12 months, depending on the renewal window chosen.
>> *---*
>>
>> Apologies that some of those got long, I wanted to preserve as much 
>> context as possible given how little material we have to work with.
>>
>> I sincerely ask anyone if they can find any further communication on 
>> these topics by Entrust. Their helpdesk has tutorials on specific software 
>> setups, but I'm not seeing any actual push for their subscribers to do 
>> anything.
>>
>> It would be very beneficial for Entrust to provide us with any 
>> information on what they've been communicating to their customers to 
>> promote shorter certificate lifespans and automation.
>>
>> - Wayne
>>
>> On Saturday, May 11, 2024 at 8:04:24 PM UTC+1 Chris Bailey wrote:
>>
>>> To Ben Wilson and the Mozilla Community:
>>>
>>>  
>>>
>>> I want to acknowledge your letter and the input from you and the 
>>> community. We agree that we have go-forward opportunities to improve.
>>>
>>>  
>>>
>>> To that end, I want to confirm our intent to provide a full written 
>>> response to you and the community prior to June 7. Until then, please 
>>> contact me directly with additional questions or feedback.
>>>
>>>  
>>>
>>> Sincerely,
>>>
>>> Chris Bailey
>>>
>>> VP-Digital Certificates
>>>
>>> Entrust
>>>
>>>  
>>>
>>> *From: *'Ben Wilson' via [email protected] <
>>> [email protected]>
>>> *Date: *Tuesday, May 7, 2024 at 10:59 AM
>>> *To: *[email protected] <[email protected]>
>>> *Subject: *[EXTERNAL] Recent Entrust Compliance Incidents
>>>
>>> Dear Mozilla Community, Over the past couple of months, a substantial 
>>> number of compliance incidents have arisen in relation to Entrust. We have 
>>> summarized these recent incidents in a dedicated wiki page: https: 
>>> //wiki. mozilla. org/CA/Entrust_Issues.  
>>>
>>> Dear Mozilla Community,
>>>
>>> Over the past couple of months, a substantial number of compliance 
>>> incidents have arisen in relation to Entrust. We have summarized these 
>>> recent incidents in a dedicated wiki page: 
>>> https://wiki.mozilla.org/CA/Entrust_Issues 
>>> <https://urldefense.com/v3/__https:/wiki.mozilla.org/CA/Entrust_Issues__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmM8uUFZ84$>.
>>>  
>>> In brief, these incidents arose out of certificate mis-issuance due to a 
>>> misunderstanding of the EV Guidelines, followed by numerous mistakes in 
>>> incident handling (including a deliberate decision to continue 
>>> mis-issuance), which have been compounded by a failure to remediate the 
>>> issues in a timely fashion in line with well-established norms and root 
>>> store requirements.
>>>
>>> Our preliminary assessment of these incidents is that while they were 
>>> relatively minor initially, the poor incident response has substantially 
>>> aggravated them and the progress towards full remediation remains 
>>> unacceptably slow. This is particularly disappointing in light of previous 
>>> incidents in 2020 (#1651481 
>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMYStPTzU$>
>>>  
>>> and #1648472 
>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1648472__;!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMQsOKu7I$>),
>>>  
>>> which arose out of similar misunderstandings of the requirements, similar 
>>> poor decision-making in the initial response, and lengthy remediation 
>>> periods that fell well below expectations. Entrust gave commitments 
>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481*c17__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMgQVGatQ$>
>>>  
>>> in those bugs to address the root problems through process improvements, 
>>> and it is concerning to see so little improvement 4 years later.
>>>
>>> In light of these recent incidents, we are requesting that Entrust 
>>> produce a detailed report of them. This report should cover in detail: 
>>>
>>>    - The factors and root causes that lead to the initial incidents, 
>>>    highlighting commonalities among the incidents and any systemic failures;
>>>    - Entrust’s initial incident handling and decision-making in 
>>>    response to these incidents, including any internal policies or 
>>> protocols 
>>>    used by Entrust to guide their response and an evaluation of whether 
>>> their 
>>>    decisions and overall response complied with Entrust’s policies, their 
>>>    practice statement, and the requirements of the Mozilla Root Program;
>>>    - A detailed timeline of the remediation process and an 
>>>    apportionment of delays to root causes; and 
>>>    - An evaluation of how these recent issues compare to the historical 
>>>    issues referenced above and Entrust’s compliance with its previously 
>>> stated 
>>>    commitments. 
>>>
>>> Finally, Entrust’s report should include a detailed proposal on how it 
>>> plans to address the root causes of these issues. In light of previous 
>>> guarantees 
>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1651481*c17__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmMgQVGatQ$>
>>>  
>>> given by Entrust in 2020 to ensure speedy remediation in future incidents, 
>>> this proposal should include:
>>>
>>>    - Clear and concrete steps that Entrust proposes to take to address 
>>>    the root causes of these incidents and delayed remediation;
>>>    - Measurable and objective criteria for Mozilla and the community to 
>>>    evaluate Entrust’s progress in deploying these solutions; and
>>>    - A timeline for which Entrust will commit to meeting these criteria.
>>>
>>> We strongly recommend that Entrust go beyond their existing commitment 
>>> <https://urldefense.com/v3/__https:/bugzilla.mozilla.org/show_bug.cgi?id=1886532*c0__;Iw!!FJ-Y8qCqXTj2!YIVy3FMEgzSPV2Nu5hQyEdywVIGxKU-_4IcqNMzywte2Ejft_WUF1bIuBSaVRS-KbyuhYwD5le7_FmgsDNT5i-TVUk08mKmM8gYsLCM$>
>>>  
>>> to offer systematic, automated solutions for effective remediation, like 
>>> ACME ARI and that it also include clear and measurable targets for the 
>>> adoption of these tools by new and existing subscribers. 
>>>
>>> This report should be submitted to Mozilla dev-security-policy mailing 
>>> list for evaluation by the community and Mozilla, who will weigh whether 
>>> Entrust’s report presents a credible and effective path towards 
>>> re-establishing trust in Entrust’s operation. Submission should be no later 
>>> than June 7, 2024.
>>>
>>> We thank community members for their engagement on these issues and look 
>>> forward to their feedback on Entrust’s report and proposed commitments.
>>>
>>>  Thanks,
>>>
>>> Ben Wilson
>>>
>>> Mozilla Root Program
>>>
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>>

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