"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. "

But we should not forget there are some CAs who feel that they can delay 
revocation of over 80.000 certificates just because of a problem with 70 of 
them.

I welcome this proposal from Mozilla.

JR

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On Friday, 20 September 2024 at 02:26, Walt <[email protected]> wrote:

> 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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