> I’m hoping that the Chrome Root Program takes the lead on this and sets a
deadline for sunsetting WHOIS based DCV.

It is possible for members of the Web PKI community besides Chrome to do
things.

On Fri, Sep 13, 2024 at 9:17 AM 'Amir Omidi' via
[email protected] <[email protected]> wrote:

> Given the way the ecosystem has recently worked, I’m hoping that the
> Chrome Root Program takes the lead on this and sets a deadline for
> sunsetting WHOIS based DCV.
>
> On Fri, Sep 13, 2024 at 09:15 Hanno Böck <[email protected]> wrote:
>
>> Hi,
>>
>> In the context of the recent .mobi whois takeover vulnerability, I had,
>> as already mentioned in another thread, checked all the whois servers
>> listed in IANAs data, and found a substantial number not answering.
>> (Those were for the TLDs cf ci dz ec gn gp hm iq ml na sb tk to uy
>> xn--lgbbat1ad8j xn--mgbtx2b xn--ygbi2ammx)
>>
>> I reported this to IANA, and also asked them about the reliability of
>> the whois server data provided by them, as I believe this is very
>> relevant for the security of whois as a domain validatin mechanism.
>>
>> Kim Davies from IANA shared this with me, and allowed me to share it
>> publicly with this group:
>>
>> > You'll note that the TLDs you gave identified with inoperative WHOIS
>> > servers are country-code top-level domains (ccTLDs). For ccTLDs,
>> > there is no global policy requirement for ccTLD managers to operate a
>> > WHOIS server, and if they do, what kind of information is provided.
>> > ccTLDs are expected to be operated under local oversight (i.e. within
>> > their respective country) and accountability for how WHOIS servers
>> > are operated is performed locally, not under ICANN policies. This is
>> > in contrast to generic top-level domains (gTLDs) where ICANN policies
>> > establish specific requirements and obligations, which are maintained
>> > through contracts. ICANN operates a contractual compliance function
>> > to address when these obligations are not met.
>> >
>> > More generally, TLD managers are obligated to keep their records
>> > up-to-date with IANA. but again in the case of country-code top-level
>> > domains IANA does not have an enforcement mechanism to ensure the
>> > ccTLD manager maintains accuracy of their records. We do verify the
>> > data is correct at the time we are assessing a change request from
>> > the TLD manager, but we cannot ensure it is consistently maintained
>> > without the ccTLD manager voluntarily participating. This is an issue
>> > that has been raised with the policy setting body for ccTLDs, the
>> > Country Code Name Supporting Organization (ccNSO), and they have
>> > recently established a working group called the Policy Gaps Analysis
>> > Working Group that is expected to study the issue in the near future.
>> >
>> > To your question as to whether IANA can guarantee control of the
>> > servers that TLD operators use to operate their TLDs. We believe we
>> > have sufficient safeguards in our processes that when we receive
>> > change requests from TLD operators, we validate they are authentic
>> > and appropriately authorized, and we confirm at that time the servers
>> > are those duly designated by them. However we are only responsible
>> > for their entries in the root zone and the associated meta-data
>> > concerning who the recognized operator of the domain is. We have no
>> > policy basis to investigate the internal workings of a TLD manager
>> > and perform assessments on whether they have full control over the
>> > components that comprise their registry operations.
>>
>> And in a further mail:
>>
>> > Briefly reading that thread, on an informal basis we have reached out
>> > to whois client vendors when we notice poor implementations. The IANA
>> > WHOIS server (whois.iana.org) actually has a "refer:" field that,
>> > when queried for a FQDN that is more specific than the data we hold,
>> > provides referrals to second-level WHOIS servers programmatically so
>> > that there is no need to hard-code TLD WHOIS server locations. With
>> > that said, WHOIS itself as a protocol is being superseded by RDAP
>> > which has a more robust discovery/referral approach and would be the
>> > preferred mechanism moving forward.
>>
>> I take away two things from this:
>>
>> * Hardcoding whois servers, like what appears to be the standard of
>>   many whois tools, is generally not a good idea. If one uses whois at
>>   all, one should query the iana whois server, and use the "refer:"
>>   field to get to the actual whois server responsible.
>>
>> * Particularly whois data for ccTLDs has limited reliability, and we
>>   have no guarantee that TLD operators keep this information updated
>>   and accurate.
>>
>> In my opinion, the latter is even more reason to consider deprecating
>> whois as a domain validation mechanism.
>>
>> I have not looked into RDAP, and do not know about its security
>> properties and whether this is used by CAs as an alternative to whois.
>>
>>
>> --
>> Hanno Böck - Independent security researcher
>> https://itsec.hboeck.de/
>> https://badkeys.info/
>>
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>>
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