Astra mortemque praestare gradatim

On Sun, Jun 8, 2025, 10:44 AM Jeremy Rowley <rowley...@gmail.com> wrote:

> I don't think OV vs. DV makes much of a difference from a CPS perspective
> as most of the CPS document is about the processes and security involved in
> running a CA, not validating the entity behind a cert. There's only two
> sections involved in identity (3.2.3 and 3.2.5) compared to domain
> validation.
>

It's definitely been a source of incidents such as the Bremerhaven is not
in Saxony one.

>
> I definitely would support seeing more description in CPS docs around
> what's automated vs. human performed. It's a good place to start.
>

As some CAs has noted this would mean process improvements have to be
rolled out with CPS changes, with a big revocation as the "prize" for
messing up. Now obviously there's a degree to which the process is the
product here, and proper identification of what process was in place at a
time is essential.

But at the same time the incentives towards vaguness are bad.


> On Sun, Jun 8, 2025 at 10:59 AM Watson Ladd <watsonbl...@gmail.com> wrote:
>
>> On Sat, Jun 7, 2025 at 2:33 PM Ryan Hurst <ryan.hu...@gmail.com> wrote:
>> >
>> > Aaron's "90 days + 1 second" example perfectly illustrates the point I
>> was making originally. This wasn't a documentation typo - it revealed a
>> fundamental gap between intended practice and actual implementation. The
>> response of changing the CPS to "less than 100 days" is exactly the race to
>> the bottom I'm concerned about.
>> >
>> > When Aaron says "we can't ever say 90 days in our CPS ever again,"
>> that's the perverse incentive in action. We're pushing CAs to make their
>> public commitments vaguer rather than pushing them to invest in systems
>> that ensure those commitments are reliable. This is the problem we need to
>> fix with better processes and automation, not with less enforceable and
>> less useful governance.
>> > The thread also reveals a troubling pattern.
>> >
>> >  We hear about "good faith errors" and inevitable human mistakes in
>> this space constantly, yet this is an industry that has automated domain
>> validation, linting of issued certificates, logging all issuance on the web
>> via certificate transparency, and manages very large-scale cryptographic
>> operations for the world. The claim that policy compliance checking can't
>> be similarly automated doesn't hold up to scrutiny.
>>
>> Let's start with disclosing which checks in the certificate issuance
>> process are done by humans.
>>
>> What's become clear over a number of incidents is that CAs can have
>> very low degrees of automation, creating the kind of situation where
>> humans will have to be on the lookout for a slight abnormality among
>> hundreds or thousands of other things, over 40 hours a week. That's
>> not something humans can do. We really need to fix this as a
>> community.
>>
>> These security relevant differences aren't in the CPS, audit reports
>> or discussed in root program addition bugs. It does seem that we're
>> barely able to get commitments to the bare minimum of BR requirements,
>> rather than CAs working to improve their processes and policies.
>>
>> >
>> > What we need is to stop treating CPSs as compliance artifacts written
>> after the fact and start making them operational documents that sit at the
>> center of how CAs work. A properly designed CPS should be machine-readable
>> on one side - directly governing issuance systems and preventing the very
>> mismatches we're debating - while remaining human-readable on the other for
>> auditors and relying parties. This is actually possible today; we just need
>> to care enough to do it.
>>
>> For DV yes, maybe. For OV and up it's going to be a harder slog. I do
>> however think that there's a very real human element here in
>> assessment.
>>
>> >
>> > After 30 years in this space, I can't look at most CPSs and understand
>> what a CA actually does. But instead of accepting this as inevitable, we
>> should be demanding that these documents serve their intended purpose:
>> clearly communicating operational reality to everyone who needs to
>> understand it.
>> >
>> > There are 8 billion people depending on this system. Are we really
>> going to allow fewer than 50 root CAs to keep treating their public
>> commitments as legal paperwork instead of operational specifications?
>> >
>> > The solution isn't weaker enforcement - it's making CPSs the living
>> center of CA operations, where policy drives practice instead of scrambling
>> to document it afterward.
>> >
>> > Ryan
>> >
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>>
>>
>>
>> Astra mortemque praestare gradatim
>>
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