SHECA agrees that a shorter certificate validity period should be implemented in the future，and supports a more reasonable validity period for certificate (24/27months) in consideration. SHECA would warmly welcome if there could be further discussions to reach to a consensus that is more appropriate for all parties.
We are with the idea proposed by HARICA that a questionnaire should be launched. SHECA votes “no” for ballot 185. Best Regards Ruby Xiong Shanghai Electronic Certification Authority co., ltd. 18F, No.1717, North Sichuan Road, Shanghai, China Tel：+86-21-36393197 Email： <mailto:[email protected]> [email protected] 发件人: Public [mailto:[email protected]] 代表 Dimitris Zacharopoulos via Public 发送时间: Monday, February 20, 2017 7:20 PM 收件人: CA/Browser Forum Public Discussion List 抄送: Dimitris Zacharopoulos 主题: Re: [cabfpub] Ballot 185 (Revised) - Limiting the Lifetime of Certificates HARICA participated in the discussion of ballot 185. Our concerns can be summarized in the following: * This proposal will raise the administrative overhead of Subscribers significantly (from where it is today). System administrators time is considered "expensive" thus, this proposal raises the cost for Subscribers. We support automation tools for web sites but there are more things to consider: * SSL/TLS certificates are used for more than web services (FTPs, LDAPs, IMAPs, POP3s, Radius, SMTP, etc). Subscribers operating such services don't currently have the necessary tools to automate the renewal process every year and it is not anticipated that such tools will exist anytime soon (even in the year to come). * Some SSL/TLS certificates are used in Federated Services which require out-of-bad distribution (a very manual process). * There are many legacy devices that don't support automation in certificate management (Wireless Access Points, VPN servers, etc). * The CA/B Forum supports and requires ONLY secure (to the best of the community's knowledge) cryptographic algorithms in the Baseline Requirements. These algorithms have a lifetime expectancy for sustaining attacks and factoring, of several years. In cases where an algorithm was proven or was even considered as insecure, appropriate deprecation measures were adopted, consistent with the vulnerabilities and threats. Of course there are lessons to be learned, and this process must be improved, even standardized. Requiring certificates to be issued every year does not substitute the necessity for appropriate deprecation measures. * We consider Google's S/MIME policy <https://support.google.com/a/answer/7300887> for certificate validity of 27 months, as the best next-step forward that should be adopted by the CA/B Forum for the Baseline Requirements. It will still raise the administrative overhead for Subscribers but it will be less aggressive and easier to adopt. For the reasons above, HARICA votes "no" for ballot 185. We would support creating an agreed-upon questionnaire by the Forum members (the same questionnaire for everyone) that will address most or all of the concerns raised in the discussion period of ballot 185. This questionnaire would be forwarded to CA Subscribers thus acquiring consistent, concrete data that will help the Forum decide future steps regarding the certificate validity period and domain validation (or re-validation). We may come back to this in a different thread, after the end of the voting period. Best regards, Dimitris Zacharopoulos. On 13/2/2017 9:18 μμ, Ryan Sleevi via Public wrote: Pursuant to the consensus on https://cabforum.org/pipermail/public/2017-February/009530.html about the nature of changes during the discussion period, and the request from Gervase on https://cabforum.org/pipermail/public/2017-February/009618.html to adjust what represents the Baseline agreement, this adjusts the effective date from 1 April to 24 August. While individual programs may choose to enact or enforce requirements prior to that, as the Baseline Requirements capture the effective point of common agreement of the bare minimum security levels, it seems appropriate that this Ballot accurately reflect that. Ballot 185 - Limiting the Lifetime of Certificates The following motion has been proposed by Ryan Sleevi of Google, Inc and endorsed by Josh Aas of ISRG and Gervase Markham of Mozilla to introduce new Final Maintenance Guidelines for the "Baseline Requirements Certificate Policy for the Issuance and Management of Publicly-Trusted Certificates" and the "Guidelines for the Issuance and Management of Extended Validation Certificates" -- MOTION BEGINS -- Modify Section 6.3.2 of the "Baseline Requirements Certificate Policy for the Issuance and Management of Publicly-Trusted Certificates" as follows: Replace Section 6.3.2, which reads as follows: """ 6.3.2. Certificate Operational Periods and Key Pair Usage Periods Subscriber Certificates issued after the Effective Date MUST have a Validity Period no greater than 60 months. Except as provided for below, Subscriber Certificates issued after 1 April 2015 MUST have a Validity Period no greater than 39 months. Until 30 June 2016, CAs MAY continue to issue Subscriber Certificates with a Validity Period greater than 39 months but not greater than 60 months provided that the CA documents that the Certificate is for a system or software that: (a) was in use prior to the Effective Date; (b) is currently in use by either the Applicant or a substantial number of Relying Parties; (c) fails to operate if the Validity Period is shorter than 60 months; (d) does not contain known security risks to Relying Parties; and (e) is difficult to patch or replace without substantial economic outlay """ with the following text: """ 6.3.2. Certificate Operational Periods and Key Pair Usage Periods Subscriber Certificates issued on or after 24 August 2017 MUST NOT have a Validity Period greater than three hundred and ninety-eight (398) days. Subscriber Certificates issued prior to 24 August 2017 MUST NOT have a Validity Period greater than thirty-nine (39) months. """ Modify Section 9.4 of the "Guidelines for the Issuance and Management of Extended Validation Certificates" as follows: Replace Section 9.4, which reads as follows: """ 9.4. Maximum Validity Period For EV Certificate The validity period for an EV Certificate SHALL NOT exceed twenty seven months. It is RECOMMENDED that EV Subscriber Certificates have a maximum validity period of twelve months. """ with the following text: """" 9.4 Maximum Validity Period for EV Certificate EV Certificates issued on or after 24 August 2017 MUST NOT have a Validity Period greater than three hundred and ninety-eight (398) days. EV Certificates issued prior to 24 August 2017 MUST NOT have a Validity Period greater than twenty seven (27) months. """ -- MOTION ENDS -- Ballot 185 - Limiting the Lifetime of Certificates Status: Final Maintenance Guideline Review Period: Start Time: 2017-02-10 00:00:00 UTC End Time: 2017-02-17 00:00:00 UTC Vote for Approval: Start Time: 2017-02-17 00:00:00 UTC End Time: 2017-02-24 00:00:00 UTC Votes must be cast by posting an on-list reply to this thread on the Public Mail List. A vote in favor of the ballot must indicate a clear 'yes' in the response. A vote against must indicate a clear 'no' in the response. A vote to abstain must indicate a clear 'abstain' in the response. Unclear responses will not be counted. The latest vote received from any representative of a voting Member before the close of the voting period will be counted. Voting Members are listed here: https://cabforum.org/members/ In order for the ballot to be adopted, two thirds or more of the votes cast by Members in the CA category and greater than 50% of the votes cast by members in the browser category must be in favor. _______________________________________________ Public mailing list [email protected] https://cabforum.org/mailman/listinfo/public
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