Thanks for the breakdown of responses so far Ben. Fully agreed on point 1. Partially agree with point 2 but there are benefits for proving that the revocation system functions in practice and having a random revocation cycle creates better habits in the consumer space.
Point 3 is unusual as revocation for compliance reasons is explicitly outlined, and that's all that this is? There isn't any new changes to the legal language required that I can see. Point 4 has been covered, being above the baseline requirements is barely noteworthy but encouraging these practices in more programs is good advice. Point 5 is a matter of scale, in prior discussions % of total active issuance were put forward as ideas. Would the CAs handling 100s of certificates per year be the ones to push the idea of it being 10% of all issuance? I'm sure the CAs can decide on which matter would suit their practices best as long as the figure is above 0. It is ultimately arbitrary unless we're moving to a % where we can be assured of coverage across a given number of years. I'm of mixed minds as to Jeremy's comment though. All regulatory practices I'm aware of propose that availability will be broken when integrity is at risk, it's also fundamental to the WebPKI as an ecosystem. Putting that aside, I would consider a CA exception to the revocation audit minimums if short-lived certificates were all that were issued. Same substance for revocation exemption in general as per the BRs. - Wayne On Wednesday, December 18, 2024 at 5:53:51 PM UTC Jeremy Rowley wrote: > I agree with point number 2. I think Mozilla should just make it clear > delayed revocations are not permitted and call it good. This is the only > industry I know where we'd propose breaking availability in the CIA > triangle just in case integrity might be compromised. Better to pull off > the band-aid and, assuming we really like 5 day revocations, either a) > require that companies use ACME to deploy certificates or b) simply state > that CAs delaying revocation past 5 days will likely be distrusted. > > On Wednesday, December 18, 2024 at 10:17:46 AM UTC-7 Ben Wilson wrote: > >> All, >> >> As part of the discussions on this proposal, namely that CAs “maintain >> and test mass revocation plans annually, including the revocation of 30 >> randomly chosen certificates within a 5-day period,” I’ve received a few >> comments via private channels, and to ensure transparency and foster >> discussion, I am sharing them here anonymously: >> >> 1. “Mozilla does not grant exceptions…” -- this is the most important >> signal that Mozilla can provide. >> >> 2. If certificate consumers want to prohibit delayed revocation, then >> they need to make it clear to CAs that they won't accept it and that they >> will kick them out of the root stores if they still do it. Don't try to >> solve this issue with indirect measures like random revocations. Just be >> straight about it and make it clear that there will be consequences for the >> very first delayed revocation and onward. >> >> 3. We will face big problems in revoking productive customer certificates >> just to test our mass-revocation plan and procedures. Our current customer >> contracts do not foresee this. While we can revoke at any time for security >> or compliance reasons, this authorization should not be used just to test >> mass-revocation. This will also require us to push out contract changes to >> our complete TLS customer base, which will take a considerable amount of >> time and effort. >> >> 4. This part of the proposal should occur within the CA/Browser Forum >> through amendments to the TLS Baseline Requirements, and not via Mozilla >> Root Store Policy. >> >> 5. Why was the number 30 chosen as a sample? Some CA operators issue >> very few certificates, while some CAs issue millions of certificates. >> >> I welcome your feedback on these points, the random sampling proposal, >> and any others. >> >> Thanks, >> >> Ben >> On Monday, December 16, 2024 at 3:02:35 AM UTC-7 [email protected] >> wrote: >> >>> Hi Ben, >>> About " annual plan testing by revoking 30 randomly chosen certificates >>> within a 5-day timeframe; and"... >>> We understand that this mean that a CA will need to randomly revoke 30 >>> certificates that most likely don't have other reason for being revoked >>> than being randomly chosen and customers will just need to "happily" accept >>> the situation... Harsh, but doable... >>> >>> About "audit report submitted under section 3.1 SHALL include an >>> attestation that the CA operator has met these mass revocation planning >>> requirements", it must be considered that the attestation letters of >>> Webtrust audit reports have a fixed format, so such addition would be added >>> most likely as a "Other matters" section, that audits can take each >>> differently. >>> >>> My question here would be if you think it's there any chance that these >>> requirements become part of the TLS BRs instead of the Mozilla Policy, I >>> see several benefits here: >>> - Checking the mass-revocation plan would be integral part of the audit >>> scope, so auditors don't need to figure out how to include it in the >>> reports... it just needs to be added to the audit criteria. >>> - The "inverse-lottery" thing could be added in the revocation timelines >>> of the BR, so there's an entry in the 5-day deadline adding a new category >>> "The certificate has been randomly chosen for revocation during an internal >>> audit". This should facilitate the contractual language to add in the >>> subscriber agreement. >>> >>> El domingo, 15 de diciembre de 2024 a las 21:51:43 UTC+1, Ben Wilson >>> escribió: >>> >>>> All, >>>> >>>> The purpose of this email is to start discussion of Mozilla GitHub Issue >>>> #276 <https://github.com/mozilla/pkipolicy/issues/276> ("Address >>>> Delayed Revocation"). We would like to collect comments and feedback on a >>>> proposal to address delayed certificate revocation from a Mozilla >>>> perspective. It builds on prior discussions and feedback regarding delayed >>>> revocation, and the proposal is meant to replace guidance currently >>>> provided on the Mozilla CA wiki >>>> <https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation>. >>>> >>>> Here is the comparison link for a proposed new section 6.1.3 in the >>>> MRSP: >>>> >>>> >>>> https://github.com/mozilla/pkipolicy/compare/51b2f702accd54cb70d52081a9e814298433495b%E2%80%A6efa8ac40ac341fb813620938ef72328a53858038 >>>> >>>> >>>> *Summary* >>>> >>>> Here are the highlights of the proposal: >>>> >>>> >>>> - Revocation must occur promptly in compliance with the timelines >>>> set in section 4.9.1 of the TLS Baseline Requirements (TLS BRs). >>>> Mozilla >>>> does not grant exceptions to these timelines. >>>> - New CA Obligations: >>>> - Educate subscribers on revocation timelines and discourage >>>> reliance on certificates in systems that cannot tolerate timely >>>> revocation. >>>> - Include contractual language requiring subscriber cooperation >>>> with revocation timelines. >>>> - Maintain and test mass revocation plans annually, including >>>> the revocation of 30 randomly chosen certificates within a 5-day >>>> period. >>>> - Beginning April 15, 2026, CA audit reports must attest to >>>> compliance with the mass revocation planning requirements. >>>> - Delayed revocation incidents must be reported per version 2.1 of >>>> the CCADB's Incident Reporting Guidelines (as currently proposed >>>> <https://github.com/mozilla/www.ccadb.org/pull/187>) >>>> - Repeated delayed revocation incidents will result in heightened >>>> scrutiny or sanctions, which may include root removal. >>>> >>>> *Background* >>>> >>>> Earlier this year, on this list, I proposed an Interim Policy to >>>> Address Delayed Revocation >>>> <https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/hXr43W3c4Gs/m/J1OAktIaAwAJ>. >>>> >>>> While the proposed interim policy provided clarity, it faced criticism >>>> regarding implementation complexity, burden on subscribers and CAs, and >>>> the >>>> feasibility of associated measures, such as transitioning delayed >>>> revocation domains to 90-day certificates. Also, there were subsequent >>>> proposals aimed at reducing certificate lifetimes and encouraging >>>> automation. See e.g. https://github.com/cabforum/servercert/pull/553. >>>> >>>> This new proposal drops proposed measures such as domain-specific >>>> tracking and subscriber attestations and instead focuses on subscriber >>>> education, mass revocation preparedness, and robust incident reporting >>>> as the primary mechanisms for improving agility and transparency regarding >>>> delayed revocation. >>>> >>>> If adopted, the proposed MRSP § 6.1.3 would replace the current >>>> guidance on delayed revocation in Mozilla’s wiki and ensure consistency >>>> with the CCADB's Incident Reporting Guidelines. >>>> >>>> I welcome your feedback on this draft proposal. Please share your >>>> thoughts, questions, or concerns to help us refine and improve it further. >>>> >>>> Thanks, >>>> >>>> Ben Wilson >>>> >>>> Mozilla Root Store >>>> >>> -- You received this message because you are subscribed to the Google Groups "[email protected]" group. To unsubscribe from this group and stop receiving emails from it, send an email to [email protected]. To view this discussion visit https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/c2290409-2ef1-4295-8f5d-13369f2dbbe1n%40mozilla.org.
