[Posting in a personal capacity, per https://wiki.mozilla.org/CA/Policy_Participants] Ben wrote: > 1. “Mozilla does not grant exceptions…” -- this is the most important signal > that Mozilla can provide. I feel compelled to express the view that Mozilla should not provide any guidance beyond this “Mozilla does not grant exceptions” statement. In other words, I think that the non-policy language at https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation should be completely removed. Not updated, not improved, and certainly not incorporated into the MRSP in some way. Completely Removed. I have formed this opinion somewhat reluctantly and primarily because I've observed one CA, despite their error being pointed out multiple times by multiple community members, continually misrepresent the non-policy language at https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation as "Mozilla policy". In one comment, that CA made the bogus claim that "the current Mozilla policy has language that allows for delayed revocation"<https://bugzilla.mozilla.org/show_bug.cgi?id=1910805#c37>. Despite now recognizing that delayed revocation "violates the Mozilla policy based on the fact that Mozilla states that CAs are expected to comply with the BRs"<https://bugzilla.mozilla.org/show_bug.cgi?id=1910805#c49>, that CA seems to want to bury that uncomfortable truth of the "most important signal" beneath Issue #276<https://github.com/mozilla/pkipolicy/issues/276>, writing "We continue to appreciate Ben's efforts to lead a productive discussion on potential policy changes in this area, and would prefer that people spend their efforts on moving such discussions forward"<https://bugzilla.mozilla.org/show_bug.cgi?id=1910805#c49>. Furthermore, by my count there were 30 "leaf-revocation-delay" bugs opened against 20 CA Owners during 2024. My recollection is that most of these revocations were delayed by choice rather than by accident. I wonder how many of these CAs have misinterpreted https://wiki.mozilla.org/CA/Responding_To_An_Incident#Revocation as a "get out of jail free card", despite the already clear assertion on that wiki page that "Mozilla does not grant exceptions to the BR revocation requirements"? Based on events so far, my conclusion is this: however well intentioned it might be, the mere existence of any language that attempts to regulate CA responses to delayed revocation incidents drowns out that "most important signal" and consequently risks doing more harm than good. IMHO, that risk can only be mitigated if that language is Completely Removed. > New CA Obligations: > - Maintain and test mass revocation plans annually, including the revocation > of 30 randomly chosen certificates within a 5-day period. Please note that there are CAs that do correctly understand that "Mozilla does not grant exceptions" and that do always strive to adhere to the mandatory BR revocation deadlines. Why should these rule-abiding CAs and their subscribers be burdened with this proposed random revocation requirement? This seems unfair, in my view. Martijn asked if it would be "fairer to only impose this random revocation requirement on those CAs that have actually had delayed revocation incidents"<https://www.mail-archive.com/[email protected]/msg01951.html>. I think that this would not only be fairer but might also act as a deterrent against CAs delaying revocations in the first place!
________________________________ From: 'Ben Wilson' via [email protected] <[email protected]> Sent: 18 December 2024 17:17 To: [email protected] <[email protected]> Subject: Re: MRSP 3.0: Issue #276: Delayed Revocation This Message Is From an External Sender This message came from outside your organization. Report Suspicious<https://us-phishalarm-ewt.proofpoint.com/EWT/v1/J5K_pWsD!CSYXMG01XQA4y_OqOfidY0g7uunnGU1GkQaJ8UyhVOg36f0VpEc-cVC8HebmxOMdCrBj9Uh_vQhJZ37JwDQygxNn39p3XsETIQ$> 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://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/issues/276__;!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhIAWoJh9g$> ("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://urldefense.com/v3/__https://wiki.mozilla.org/CA/Responding_To_An_Incident*Revocation__;Iw!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhKQ7b-mrQ$>. Here is the comparison link for a proposed new section 6.1.3 in the MRSP: https://github.com/mozilla/pkipolicy/compare/51b2f702accd54cb70d52081a9e814298433495b%E2%80%A6efa8ac40ac341fb813620938ef72328a53858038<https://urldefense.com/v3/__https://github.com/mozilla/pkipolicy/compare/51b2f702accd54cb70d52081a9e814298433495b**Befa8ac40ac341fb813620938ef72328a53858038__;4oCm!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhJ_T6DLbA$> 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://urldefense.com/v3/__https://github.com/mozilla/www.ccadb.org/pull/187__;!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhLuTONaHw$>) * Repeated delayed revocation incidents will result in heightened scrutiny or sanctions, which may include root removal. Background Earlier this year, on this list, I proposed an Interim Policy to Address Delayed Revocation<https://urldefense.com/v3/__https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/hXr43W3c4Gs/m/J1OAktIaAwAJ__;!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhLzvBpyuQ$>. 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<https://urldefense.com/v3/__https://github.com/cabforum/servercert/pull/553__;!!J5K_pWsD!06eCiH-z9p5yhGa9Bgvk0E4usFSOxLD34_mw2rgfrCsDCHV0wNZcjxMPgPRh3Gcm9DLRYYkoCu9Iqrz2PhLDbgvh4g$>. 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]<mailto:[email protected]>. 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