Hi all,


Thanks Ben for this proposal. Overall I find it well thought out and it

moves things in the right direction. Publishing the requests received from

customers will do a lot to help with what has until now been a series of

vague justifications from CAs on why revocation was delayed.



I agree with Walt that every FQDN should be a separate request with its own

justification; excess paperwork is a great way to drive a point home with

some corporates.



Moving delayed FQDNs to shorter term certificates is a nice tradeoff, a

clever idea! I think 90 days in the first instance is about right, but if

it happens again the FQDN should be moved to STAR certificates. If it

happens a third time then I'm not quite sure what to do other than say 'are

we absolutely positively sure WebPKI is right for this application?'

I don't think specific technical standards, such as ACME, as Walt suggested

should be written into this proposal. A customer should generally be free

to manage their certificates however they like. If they choose to manage 90

day (or even 7 day) certs manually, that's on them.



Q

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On Fri, 20 Sept 2024 at 07:25, Suchan Seo <[email protected]> wrote:



>

> I think 90 days max can stop it, because curreny proposal makes each and

> all domains included in delayed certificate have 90 days max, so clients

> likely wouldn't add domain unless it's required.

> 2024년 9월 20일 금요일 오전 10시 26분 5초 UTC+9에 Walt님이 작성:

>

>>

>> I think broadly this is a good decision.

>>

>> As Matt mentioned, I really *really* hope there are no CAs that think

>> they shouldn't revoke by default, given the events of the past few months.

>>

>> I'd go a step further than that proposal however and suggest that *each

>> and every* delayed revocation request requires a separate action to be

>> made.

>>

>> For example, if I had:

>>

>>    - acme.example.com

>>    - example.com

>>    - *.example.com

>>

>> as three separate certificates that I needed delayed revocation on, I as

>> the officer of Acme would need to submit three separate signed requests as

>> Ben mentioned on the critical nature of the system etc. The goal here is to

>> avoid a process where a company just goes "critical services, don't revoke"

>> on a certificate set that is hundreds or thousands of certs. There's a

>> potentially separate conversation to be had about subscribers not

>> understanding the meaning of "CA can revoke within 24/120h" in the

>> subscription agreement they're all agreeing to (at least I hope), but

>> that's somewhat out of scope for this discussion.

>>

>> Maybe a bit of a stretch goal here (especially since this would generally

>> run counter to the incentives of the average CA [in that profit is more or

>> less the priority by virtue of them being a for profit business) is that

>> not only do any of these limited domains only allow a 90 day certificate,

>> but a CA can only issue them using ACME or other fully automated protocols

>> for x amount of time. Since this also has downstream impact in terms of

>> EV/DV certs, this is a much harder sell, but as a counter point on why this

>> may not be necessary if the 90 day max lifespan is implemented, a 90 day

>> long certificate is rotating frequently enough that just from pure hassle

>> alone it may make sense to switch to automating the certificates, whether

>> or not enforcing ACME or similar is a mandated part of that list.

>> On Thursday, September 19, 2024 at 5:44:15 PM UTC-7 Matt Palmer wrote:

>>

>>> On Thu, Sep 19, 2024 at 03:53:16PM -0600, 'Ben Wilson' via

>>> [email protected] wrote:

>>> > 1.

>>> >

>>> > Clarification of existing requirements

>>> > We would be more explicit about what would be required for delayed

>>> > revocation. Some ideas include:

>>> > 1.

>>> >

>>> > Explicitly clarifying that CAs must revoke certificates by default,

>>> > that any delayed revocation must be the result of an explicit request

>>> by

>>> > the subscriber, containing the necessary information, and meeting the

>>> > requirements under such interim policy;

>>>

>>> If there are any CAs that currently think that they *shouldn't* revoke

>>> certificates by default, I would be very deeply concerned.

>>>

>>> > 2.

>>> >

>>> > That subscriber requests contain a clear claim or explanation about

>>> > the critical nature of the system and why timely revocation is

>>> > not possible

>>> > (more detailed requirements to be discussed);

>>> > 3.

>>> >

>>> > That the requests are signed by a company officer, or similar legal

>>> > representative, stating that the information in the request is

>>> > accurate to

>>> > the best of their knowledge;

>>> > 4.

>>> >

>>> > That the information contained in the subscriber’s request be

>>> > accurate to the CA’s understanding (e.g. not materially contradicted

>>> by

>>> > other facts known to the CA);

>>> > 5.

>>> >

>>> > That each granted request be published for the community (and

>>> > Mozilla) to scrutinize (allowing CAs to redact PII prior to

>>> publication);

>>> > and

>>>

>>> Requiring publication of the detailed reasons for delayed revocation as

>>> part of a delayed revocation report would be a great benefit to the

>>> WebPKI, I believe.

>>>

>>> > 6.

>>> >

>>> > That CAs be required to produce summary statistics in their reports

>>> > (alongside the individual granted requests) detailing how many

>>> requests

>>> > were received, how many were well-formed, how many were granted, etc.

>>>

>>> This, too, would be valuable information to improve the visibility and

>>> resilience of the WebPKI.

>>>

>>> > Consequences of Delayed Revocation

>>> > We believe that if a domain hosts critical infrastructure that cannot

>>> > tolerate timely revocation, then it is deeply damaging to the web PKI.

>>> In

>>> > order to help these domains transition to effective certificate

>>> management

>>> > practices and automated tooling, we propose that domains that are

>>> granted

>>> > delayed revocation must then be limited to shorter-lifetime

>>> certificates as

>>> > a consequence of such decision. This also ensures that future

>>> revocations

>>> > impacting such domains have much less impact.

>>>

>>> I believe this would be an admirable improvement, because as you say, a

>>> shorter lifetime for such certificates reduces the period of time in

>>> which a known-flawed certificate could be misused, if revocation were

>>> significantly delayed for some reason.

>>>

>>> Taking this thought to its logical conclusion, if a certificate is so

>>> important that revocation is too dangerous to execute within the

>>> strictures of the WebPKI, it should be moved to a seven-day lifetime,

>>> which as I understand it means that the CA is no longer required to

>>> revoke.

>>>

>>> > Concretely, the domains accepted for delayed revocation by a CA are

>>> > already public. If this proposal were to be adopted, root programs

>>> would

>>> > manage a shared list of such domains (e.g. via the CCADB) and require

>>> CAs

>>> > to limit the lifetimes of certificates issued to these domains (e.g.

>>> to 90

>>> > days).

>>>

>>> By "domain", are you referring to FQDN (ie sAN values) or the associated

>>> eTLD+1? I would expect it to be FQDN, based on my understanding of the

>>> intent, but it's worth clarifying, IMO, to ensure everyone's on the same

>>> page.

>>>

>>> - Matt

>>>

>>> --

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