Hello,

I appreciate your feedback.  Thank you for the review. Let me address the core 
questions.

> As I understand the problem, it is that the MNOs do not offer any open way 
> for enterprise systems to authenticate over RADIUS.

The problem is more fundamental than API access. MNOs actively protect 
HLR/HSS/UDM as a security perimeter — no MNO will permit an enterprise to 
originate MAP/Diameter/SBI queries directly. More importantly: MNO subscribers 
already offload to enterprise Wi-Fi today, but do so using separate enterprise 
credentials (captive portals, guest SSIDs) with no relationship to their MNO 
subscription. The MNO loses all policy visibility, QoS control, and service 
continuity the moment the device touches enterprise Wi-Fi. When that subscriber 
moves between APs on a VoWiFi call, re-authentication takes 1,800–2,900 ms — a 
guaranteed dropped call every time. This is the current production reality in 
virtually every enterprise deployment.


> What MNOs are going to be actively interested in doing this?

MNOs are already experiencing this pain — they bear subscriber complaints for 
VoWiFi call drops on infrastructure they have no control over. But beyond the 
quality problem, placing the MNO in the active authentication loop for 
enterprise Wi-Fi offload is not architecturally viable at scale. A single MNO 
may have subscribers offloading across tens of thousands of enterprise venues 
simultaneously. Requiring a live HSS/HLR round-trip for every 802.1X 
authentication event across that estate is operationally and economically 
unrealistic — the MNO backend was never designed to serve as a real-time RADIUS 
endpoint for arbitrary third-party venues. This is precisely why an offline, 
venue-hosted solution is the correct architecture: the MNO provisions once, the 
MEA authenticates locally indefinitely, and the MNO backend is never in the 
per-authentication critical path.


> If I was trying to solve this, I'd work with an MNO to enable a vetted 
> on-prem RADIUS proxy.

This assumes MNOs would be receptive to opening their authentication 
infrastructure to enterprise venues. In practice, the opposite is true — and 
for well-understood reasons.

An MNO's HLR/HSS/UDM is among the most tightly controlled infrastructure in any 
operator network. It holds Ki for every subscriber. Permitting an enterprise 
venue to originate authentication queries against it — even through a vetted 
proxy — means the MNO must now trust the security posture, availability, and 
operational integrity of every enterprise it connects to. A single compromised 
enterprise proxy becomes a vector into the MNO's subscriber identity 
infrastructure. No MNO security or legal team will accept that exposure. This 
is not a business negotiation problem; it is a fundamental trust boundary.

Beyond the security perimeter: a single MNO has subscribers offloading across 
tens of thousands of enterprise venues simultaneously. Routing every 802.1X 
authentication event for every Wi-Fi offload session through a live HLR/HSS 
round-trip across that entire estate is not operationally viable. The MNO 
authentication backend was never dimensioned for this traffic pattern.

And even if both of those objections were somehow resolved, a RADIUS proxy 
still cannot solve the problem this draft addresses. Fast intra-enterprise 
handoff requires PMK-R1 key material to be pre-positioned at the target AP 
before the roam occurs — that requires a local R0 Key Holder on the enterprise 
edge. With a proxy, the MSK is produced on the MNO-side server; there is no 
local entity to derive and distribute PMK-R1 to enterprise APs. Every AP 
transition for a VoWiFi call would still require a full MNO round-trip, costing 
1,800–2,900 ms — a guaranteed dropped call. The fast handoff problem is 
structurally unsolvable with a proxy architecture, regardless of how the proxy 
is vetted or provisioned.



> Why are there any protocol changes required?

Because every existing SIM-based EAP method — EAP-SIM, EAP-AKA, EAP-AKA', 
EAP-AKA' FS — requires a live query to the subscriber's home HSS/HLR/UDM to 
obtain RAND/AUTN/XRES. No query, no authentication. EAP-WSIM replaces that live 
query with a WSIM SIM card acting as a self-contained Authentication Centre on 
the enterprise edge. That replacement requires a new protocol.



> Has MILENAGE-ECDH-FWD been to CFRG? It doesn't sound quantum-safe.

CFRG submission is the intended next step pending initial EMU WG feedback, and 
I would welcome that review.

On quantum safety: the framing of the question warrants examination. No 
currently deployed MNO SIM-based EAP method is quantum-safe. EAP-SIM uses 
HMAC-MD5/SHA1-based PRFs over a shared symmetric key. EAP-AKA and EAP-AKA' use 
MILENAGE, whose f1–f9 functions are built on AES-128 — providing approximately 
64 bits of security against a quantum adversary via Grover's algorithm, not 
128. Critically, none of these methods provide forward secrecy: compromise of 
the long-term shared key Ki retroactively exposes all past sessions.

To be precise about EAP-WSIM's current construction: ECDH P-256 is not 
quantum-safe. Shor's algorithm running on a sufficiently capable quantum 
computer breaks elliptic curve discrete logarithm efficiently, meaning the 
forward secrecy guarantee does not hold in a post-quantum threat model. The 
MILENAGE component (AES-128) retains approximately 64-bit security under 
Grover, consistent with EAP-AKA.

However, EAP-WSIM is a new protocol. Unlike EAP-AKA and EAP-AKA', which carry 
the design constraints of 2G/3G-era SIM hardware, EAP-WSIM has no legacy 
deployment to preserve compatibility with. We therefore intend to update the 
construction to replace ECDH P-256 with ML-KEM (FIPS 203) as the key 
encapsulation mechanism, making EAP-WSIM the first SIM-based EAP method to 
provide both offline mutual authentication and post-quantum forward secrecy. 
This is the right moment to build this correctly — standardizing a new method 
with known quantum vulnerability would be a missed opportunity.

If the WG has a view on ML-KEM parameter selection or hybrid classical/PQ 
construction, that input would be welcome as part of this discussion.



> How/why do client systems trust this local server?

Through pre-association validation (BAD-MEA guard): the MNO application on the 
UE validates a hardware-backed MEA identity proof against the MNO's own CA 
before any EAP exchange begins. A rogue authenticator without a valid 
MNO-issued certificate is refused before any SIM credential is disclosed.


Happy to go deeper on any of these. Draft: 
https://datatracker.ietf.org/doc/draft-gupta-emu-eap-wsim/

Praveen Gupta
[email protected]


-----Original Message-----
From: Michael Richardson <[email protected]> 
Sent: Wednesday, June 17, 2026 10:48 AM
To: Praveen Gupta <[email protected]>; [email protected]
Subject: Re: [Emu] Re: New Individual Draft: draft-gupta-emu-eap-wsim-00 
(EAP-WSIM)


I've only browsed your I-D.

Praveen Gupta <[email protected]> wrote:
    > I would appreciate your interest and feedback on this very important
    > solution gap for MNO-devices offloading to Enterprise-WIFI.

As I understand the problem, it is that the MNOs do not offer any open way for 
enterprise, (or other EAP-SIM capable systems) to authenticate over
radius.   I'm not seeing how anything you've proposed solves that problem.

    > ─── What EAP-WSIM Addresses ──────────────────────────────────
    > EAP-WSIM proposes a venue-side Wireless SIM (WSIM) hardware
    > authenticator approved by the MNO, which holds keying material on-card
    > and runs MILENAGE-ECDH-FWD entirely offline-without contacting the MNO
    > backend during authentication. Key properties:

Sounds like an interesting product/service.
I don't know why it a "hardware authenticator" vs a virtual appliance to be
run on-prem.   What MNOs are going actively interested in doing this?
I think it's gonna be a pretty hard-sell to almost every CFO.
The people/enterprises who would most benefit from this, are likely least able 
to use it.

    > For enterprises: A single WSIM-provisioned authenticator (MEA) supports
    > any MNO subscriber without per-operator AAA integration. Operator
    > policy, SSID identity, and charging correlation hooks are preserved.

I guess, backend through the MNO to the mobile (formerly "SS7") network.
If I was trying to solve the problem as you outlined, then I'd be working with 
an MNO to enable them to offer some kind of vetted onboarding for an on-prem 
radius proxy.

    > I welcome review and discussion on:

    >   1. Whether the problem statement and gap analysis resonate with the
    > WG 2. Technical comments on the MILENAGE-ECDH-FWD construction and key
    > derivation 3. Relationship to ongoing EAP method work in the WG
    > 4. Interest in co-authoring or adopting as a WG item

Why are there any protocol changes required?
Which desktop/mobile OS vendors have committed to implementing EAP-WSIM?
Why isn't EAP-SIM/AKA/AKA' with a radius proxy into the MNO enough?
To me, this looks like MILEANGE-ECDH-FWD looking for a problem that it can 
solve.

}   No MNO backend
}   contact occurs at any point during the authentication exchange.

So what really is the point?
Does the EAP server have a "WSIM" per subscriber?  How are those related to the 
(E)SIM card in my phone from my carrier?

Has MILEAGE-ECDH-FWD been to CFRG?
It doesn't sound quantum-safe to me.
While EAP-AKA is essentially shared symmetric key, so it is.

How/why do client systems trust this local server?

--
]               Never tell me the odds!                 | ipv6 mesh networks [
]   Michael Richardson, Sandelman Software Works        | network architect  [
]     [email protected]  http://www.sandelman.ca/        |   ruby on rails    [

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