Hi, Arabella
Thank you for your professional reply. SHECA will rigorously verify the two 
points you mentioned!
Best Regards!

On Friday, October 10, 2025 at 9:00:56 PM UTC+8 Arabella Barks wrote:

> Alvin,
>
> I believe reissuing without additional DCV is compliace if SHECA ensures:
> - The domain name's status is not one of the following: expired, or 
> re-registered after expiration within the TLS validity period pending 
> revocation (the registration date can be checked using WHOIS);
> - reissuing CSR generated by subscriber, not generated by SHECA;
>
> I believe it's compliance based on two prerequisites:
> - CSR noncompliance does not affect the authenticity of the user's 
> intention to apply for SSL;
> - BR defines a 13-month DCV for reuse and does not impose such additional 
> conditions.
>
> Correction is welcome.
>
> Arabella Barks
> On Friday, October 10, 2025 at 8:13:01 PM UTC+8 Alvin Wang wrote:
>
>> Hi All,
>> SHECA would like to confirm a question with the community: In accordance 
>> with the current provisions of BR 4.2.1, the verification materials for 
>> domains or IPs have a 398-day reusability period. Regarding the 
>> certificates that SHECA needs to revoke this time, for those certificates 
>> whose organizational and domain verification materials are still within the 
>> validity period, is it allowed to reissue them directly under the original 
>> orders without re-conducting domain and organizational verification? And 
>> does this practice comply with BR requirements?
>> Best Regards!
>>
>> On Friday, October 10, 2025 at 7:38:41 PM UTC+8 Alvin Wang wrote:
>>
>>> Hi, Linh
>>> SHECA recognizes that the forum discussions are rooted not only in a 
>>> supervisory intent but also in a desire to support the refinement of our 
>>> work. SHECA has consistently upheld the principles of openness and 
>>> transparency, with no intention of withholding any information. SHECA 
>>> greatly values the attention and discussions surrounding this matter, and 
>>> kindly asks that all participants maintain an objective stance throughout 
>>> our communications. SHECA deems it inappropriate to make judgments without 
>>> a factual basis.
>>>
>>> Inspection of API users, SHECA attaches great importance to it and 
>>> carried out a review immediately. The specific situation is explained as 
>>> follows: During the National Day holiday (October 1st - October 8th), as 
>>> the team conducted the first round of inspection through remote 
>>> collaboration, due to the limitations of resource allocation and remote 
>>> communication efficiency during the holiday, the initial inspection scope 
>>> failed to fully cover all API types. On the first working day after the 
>>> holiday (October 9th), we have arranged the R&D team to conduct a detailed 
>>> and comprehensive secondary inspection of all logs.
>>> After final confirmation, there are two partners that have called the 
>>> relevant APIs: one is Xinnet, which has been reported previously, and the 
>>> other is China Mobile Cloud. Among them, China Mobile Cloud uses an old - 
>>> version API which was not included in the standard API list for the first 
>>> round of inspection, resulting in omissions during the first round of 
>>> inspection.
>>>
>>> APIs Involved in Xinnet:
>>> /open-api/v2/order/download-zip
>>> Function: Download certificates in all formats 
>>> Subscriber-provided parameters: Private key and order number 
>>> SHECA returns: An encrypted ZIP file containing certificates in various 
>>> formats, including Nginx, Tomcat, and Apache.
>>>
>>> /open-api/v2/tools/gen-csr
>>> Function: Generate a certificate request (CSR)
>>> Subscriber-provided parameters: None
>>> SHECA returns: Certificate request (CSR) and private key.
>>>
>>> Certificates Involved in Xinnet:
>>> All valid certificates issued under the two roots (Xinnet DV SSL, Xinnet 
>>> OV SSL) before 24:00 on October 9, 2025. SHECA will publish the relevant 
>>> certificate list in subsequent cases.
>>>
>>> APIs Involved in China Mobile Cloud:
>>> /openApi/v1/order/getCertInfo
>>> Function: Download certificates in all formats
>>> Subscriber-provided parameters: Private key and order number
>>> SHECA returns: An encrypted ZIP file containing certificates in various 
>>> formats, including Nginx, Tomcat, and Apache.
>>>
>>> Certificates Involved in China Mobile Cloud:
>>> All valid certificates issued under China Mobile Cloud accounts before 
>>> 24:00 on October 9, 2025. 
>>> SHECA will publish the relevant certificate list later in the cases.
>>>
>>> Next Rectification Measures:
>>> The three APIs have been offline according to the specified time nodes.
>>> SHECA will revoke the affected certificates and contact customers for 
>>> replacement according to the MRIP&TP. Currently, communication with 
>>> customers has begun.
>>>
>>> Point-to-point Responses to Some Questions You Mentioned:
>>> Question 1
>>> Regarding the tool for converting certificate formats included in the 
>>> directory for downloading certificates, SHECA implements it using 
>>> Javascript on the front - end. It has been made clear in the previous 
>>> discussion that this does not violate the BR regulations. SHECA has 
>>> provided the relevant code in the attachment(convert.txt) for community 
>>> review. Although SHECA has issued many ICAs, according to SHECA's internal 
>>> log screening, no other partners except Xinnet and China Mobile Cloud have 
>>> been found to call the above APIs.
>>> Question 2
>>> Currently, SHECA has taken the above APIs offline, and plans to revoke 
>>> all subscriber certificates within validity related to the APIs.
>>> Question 3
>>> SHECA would like to know through which platform you purchased the 
>>> certificate, so that SHECA can conduct verification accordingly.
>>> Question 4
>>> First of all, SHECA has not received any notification regarding the 
>>> compromise of subscribers' private keys so far.
>>> Secondly, it should be clearly stated that SHECA has never recorded any 
>>> subscribers' private keys in any form, and this is a security baseline we 
>>> strictly adhere to. Partial logs of the aforementioned two APIs of SHECA 
>>> are provided in the attachment(log1.png&log2.png), proving that the private 
>>> keys are independently kept by users themselves.
>>> Finally, out of the principle of prudence and for the protection of 
>>> subscribers' rights and interests, SHECA has published announcements of the 
>>> mass revocation event to remind users to immediately cease their current 
>>> private keys, and not to use the CSR corresponding to this private key to 
>>> apply for any certificate on any platform, so as to mitigate potential 
>>> risks.
>>> If you have any questions, you are welcome to discuss with us at any 
>>> time. Thank you!
>>> On Thursday, October 9, 2025 at 1:34:40 AM UTC+8 Linh Bach Quang wrote:
>>>
>>>> Hi Alvin,
>>>>
>>>> To obtain a more complete view of the matter, I purchased an SHECA SSL 
>>>> certificate and discovered several issues:
>>>>
>>>> 1.The delivered materials included both public and private key 
>>>> information in multiple certificate formats, which corresponds to the 
>>>> /open-api/v2/order/download-zip interface.
>>>> [image: Magic1.png]
>>>>
>>>> 1.1 There was also an instruction txt file that contained a tool 
>>>> guiding customers to upload their private keys for certificate format 
>>>> conversion (certificate installation reference: 
>>>> https://www.yuque.com/sheca/kfxgzb). In one of the pages, it includes 
>>>> an online certificate format conversion tool that receives users’ uploaded 
>>>> private keys. https://www.yuque.com/sheca/kfxgzb/gndrhghm75h205vl
>>>>
>>>> [image: Magic2.png]
>>>>
>>>> [image: Magic3.png][image: Magic4.png]
>>>>
>>>>
>>>> 1.2 In your response above, you mentioned only two partners 
>>>> corresponding to two ICAs are using the relevant API
>>>>
>>>> -Xinnet DV SSL
>>>>
>>>> -Xinnet OV SSL
>>>>
>>>> However, it looks like the situation may differ significantly from what 
>>>> you described. Please reconfirm the scope of affected certificates and 
>>>> whether any other interfaces have access to users’ private keys.
>>>>
>>>> I have seen that under the UCA Global G2 Root (
>>>> https://crt.sh/?caid=36110), there are more than 15 ICAs, including 
>>>> SHECA-branded certificates. And the current observations indicate they all 
>>>> present this risk.
>>>>
>>>> [image: Magic5.png][image: Magic6.png]
>>>>
>>>>
>>>>
>>>> Based on the above information, it is also needed to consider whether 
>>>> the response from the SHECA team is genuine.
>>>>
>>>>
>>>> 2.The interface /open-api/v2/tools/gen-csr, used for generating private 
>>>> keys and CSRs, does provide a newPassword parameter to encrypt the private 
>>>> key, but it is not mandatory. For SHECA certificates applied from its 
>>>> partners, the private keys were encrypted using the default weak password 
>>>> 123456.
>>>>
>>>> [image: Magic7.png]
>>>>
>>>> 3.There was not any Subscriber Agreement during the ordering process.
>>>>
>>>> *>These API were authorized by partners when they were provided to 
>>>> them. Furthermore, when partners provided these methods to subscribers, 
>>>> they also signed corresponding subscriber agreements to obtain user 
>>>> authorization. Therefore, SHECA believes that the reason for revocation in 
>>>> this incident does not apply to the third point of 4.9.1.1.*
>>>>
>>>>
>>>> 4.Both the /open-api/v2/tools/gen-csr and 
>>>> /open-api/v2/order/download-zip interfaces have access to users’ private 
>>>> keys. How does SHECA ensure that these private keys (CSRs) have not been 
>>>> used to request additional certificates beyond the intended scope? And how 
>>>> will SHECA prevent any continued use of these private keys in the future?
>>>>
>>>> Regards.
>>>>
>>>> Vào lúc 19:25:33 UTC+7 ngày Thứ Tư, 8 tháng 10, 2025, Alvin Wang đã 
>>>> viết:
>>>>
>>>>> Hi,everyone!
>>>>> 1. Reply to Matt's comment
>>>>> SHECA adopted this solution to provide partners with public and 
>>>>> private keys for identity authentication, and used JWT to verify 
>>>>> partners' 
>>>>> API requests, because it can effectively prevent unauthorized data access 
>>>>> and ensure security. This authentication solution is widely used by 
>>>>> Internet companies as a security verification method for external API 
>>>>> provision. That's why this solution was  considered by SHECA.
>>>>>
>>>>> 2. Which BR Regulation Should be Applied to the Revocation Reason
>>>>> 2.1 Regarding Bastian's Description
>>>>> "According to the definition of 'Key Compromise' in the BR, is the CA 
>>>>> considered an unauthorized person? If so, this would trigger revocation 
>>>>> within 24 hours in accordance with 4.9.1.1."
>>>>> These API were authorized by partners when they were provided to them. 
>>>>> Furthermore, when partners provided these methods to subscribers, they 
>>>>> also 
>>>>> signed corresponding subscriber agreements to obtain user authorization. 
>>>>> Therefore, SHECA believes that the reason for revocation in this incident 
>>>>> does not apply to the third point of 4.9.1.1.
>>>>>  
>>>>> 2.2 Regarding Matt's Description
>>>>> "If that CSR contains the public key corresponding to the returned 
>>>>> private key (and I'm not sure how it could be anything else), and that 
>>>>> CSR 
>>>>> is later used by SHECA to issue a publicly-trusted certificate that 
>>>>> contains serverAuth or anyEKU, that would appear to be a BR violation, 
>>>>> per 
>>>>> the last paragraph of 6.1.1.3:
>>>>>  
>>>>> If the Subscriber Certificate will contain an extKeyUsage extension 
>>>>> containing either the values id-kp-serverAuth [RFC5280] or 
>>>>> anyExtendedKeyUsage [RFC5280], the CA SHALL NOT generate a Key Pair on 
>>>>> behalf of a Subscriber, and SHALL NOT accept a certificate request using 
>>>>> a 
>>>>> Key Pair previously generated by the CA.
>>>>> This violation requires revocation within 24 hours, per 4.9.1.1, point 
>>>>> 4."
>>>>>
>>>>> SHECA believes that 4.9.1.1 point 4 is not applicable to this case. 
>>>>> This is because the generation method of the public and private keys has 
>>>>> not been compromised, and external attackers cannot calculate the 
>>>>> subscriber's private key from the public key through any known methods 
>>>>> (including those mentioned in 6.1.1.3(5)).
>>>>>  
>>>>> 2.3 Summary
>>>>> SHECA acknowledges that the aforementioned two interfaces do violate 
>>>>> the following rules in BR 6.1.1.3:
>>>>> "If the Subscriber Certificate will contain an extKeyUsage extension 
>>>>> containing either the values id-kp-serverAuth [RFC5280] or 
>>>>> anyExtendedKeyUsage [RFC5280], the CA SHALL NOT generate a Key Pair on 
>>>>> behalf of a Subscriber, and SHALL NOT accept a certificate request using 
>>>>> a 
>>>>> Key Pair previously generated by the CA."
>>>>> As well as BR 9.6.3:
>>>>> "The Applicant is obligated and warrants to take all reasonable 
>>>>> measures to ensure control, confidentiality, and proper protection at all 
>>>>> times of the private key corresponding to the public key included in the 
>>>>> requested Certificate (as well as any related activation data or devices, 
>>>>> such as passwords or tokens);"
>>>>> SHECA believes that the most appropriate revocation reason for this 
>>>>> case is per 4.9.1.1, point 16. Although there is no risk in the method 
>>>>> SHECA uses to generate CSRs and private keys, the act of SHECA providing 
>>>>> APIs for generating CSRs and private keys does carry certain risks. In 
>>>>> the 
>>>>> event that SHECA's system is compromised, it could lead to the leakage of 
>>>>> subscribers' private keys. SHECA will comply with BR regulations, revoke 
>>>>> all certificates applied for through the above two API interfaces within 
>>>>> five days, and require users to generate new CSRs and private keys to 
>>>>> reapply for certificates.
>>>>>  
>>>>> SHECA will open a case on Bugzilla to report follow-ups.
>>>>> Please feel free to ask if you have any other questions.
>>>>>
>>>>> On Wednesday, October 8, 2025 at 7:19:54 AM UTC+8 Matt Palmer wrote:
>>>>>
>>>>>> On Tue, Oct 07, 2025 at 04:52:56AM -0700, Alvin Wang wrote: 
>>>>>> > SHECA provides partners with public and private keys for 
>>>>>> authenticating 
>>>>>> > their API requests. 
>>>>>>
>>>>>> That seems like a terrible idea, but would appear to be outside the 
>>>>>> remit of the BRs. 
>>>>>>
>>>>>> > /open-api/v2/order/download-zip 
>>>>>> > Function: Download certificates in all formats 
>>>>>> > Subscriber-provided parameters: Private key and order number 
>>>>>>
>>>>>> ... again, doesn't appear to be a BR violation, but seems to be an 
>>>>>> even more terrible idea. 
>>>>>>
>>>>>> > /open-api/v2/tools/gen-csr 
>>>>>> > Function: Generate a certificate request (CSR) 
>>>>>> > Subscriber-provided parameters: None 
>>>>>> > SHECA returns: Certificate request (CSR) and private key. 
>>>>>>
>>>>>> If that CSR contains the public key corresponding to the returned 
>>>>>> private key (and I'm not sure how it could be anything else), and 
>>>>>> that 
>>>>>> CSR is later used by SHECA to issue a publicly-trusted certificate 
>>>>>> that 
>>>>>> contains serverAuth or anyEKU, that _would_ appear to be a BR 
>>>>>> violation, 
>>>>>> per the last paragraph of 6.1.1.3: 
>>>>>>
>>>>>> > If the Subscriber Certificate will contain an extKeyUsage extension 
>>>>>> > containing either the values id-kp-serverAuth [RFC5280] or 
>>>>>> > anyExtendedKeyUsage [RFC5280], the CA SHALL NOT generate a Key Pair 
>>>>>> on 
>>>>>> > behalf of a Subscriber, and SHALL NOT accept a certificate request 
>>>>>> using 
>>>>>> > a Key Pair previously generated by the CA. 
>>>>>>
>>>>>> This violation requires revocation within 24 hours, per 4.9.1.1, 
>>>>>> point 4. 
>>>>>>
>>>>>> - Matt 
>>>>>>
>>>>>

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