Pre-validation is a common practice.  Here is scenario:

 

1 –         a. Customer signs a contract with domains listed therein, or 

b. signs up for an account, obtains a username/password and submits domain 
names.

2 – CA starts the domain validation process

3 – Customer submits CSR

4 – CA completes any remaining validation steps and verifies that process has 
not exceeded any applicable timeframes

5 – CA issues certificate 

 

Ben Wilson, JD, CISA, CISSP

VP Compliance

+1 801 701 9678



 

From: Public [mailto:[email protected]] On Behalf Of Ryan Sleevi via 
Public
Sent: Friday, May 19, 2017 4:08 PM
To: Peter Bowen <[email protected]>
Cc: Ryan Sleevi <[email protected]>; CA/Browser Forum Public Discussion List 
<[email protected]>
Subject: Re: [cabfpub] Preballot - Revised Ballot 190

 

 

 

On Fri, May 19, 2017 at 6:00 PM, Peter Bowen <[email protected] 
<mailto:[email protected]> > wrote:

Yes, it does.  We know that CAs can generate keys on behalf of the subscriber, 
so it is clear that a public key is not required.  This means that a CA could 
take the request for “issue a certificate to example.com <http://example.com> 
”, do validation and key generation, throw away the private key, issue the 
cert, and end up with a “pre-validated” domain.  This is compliant.  The 
generated cert could have some flag in it, similar to a pre-cert, that makes it 
unusable for any real world purpose, and it would still be fine.  But this is 
silly.  We don’t want to have hoop jumping for no discernible value.

Can you suggest a change that you feel would make it clear that CAs may 
validate identities (organizations, domains, etc) independent of issuing 
certificates and use the documents and data gathered during such validation for 
future issuance, subject to the aging requirement of 4.2.1?  I would suggest a 
change myself, but I’m not quite clear which part of the BRs you feel prevents 
this today.

 

The BRs are gated on the concept of an Applicant - all of the validation is 
done in concert and connection with an Applicant.

 

I'm not sure how it makes sense for CAs to have, say, a prevalidated set of 
organizations, any of which can apply and thus reuse the information.

 

Put differently: Do you think it would be BR conformant if a CA looked through 
CT, determined which organizations had OV/EV certs, worked through QIIS/QGIS's 
to 'prevalidate' the organizational information related to it, and then 
approached all customers with the remark "We can give you a certificate in 30 
seconds?"

 

It may be that the answer is yes - that the extent of the CAs obligations (to 
validate the documents and domain, in absentia of an Applicant) are met.

It may be that the answer is no - that a CA cannot begin doing some form of 
validation until contacted by an Applicant.

 

But I think understanding the specific answer to this scenario can help inform 
whether or not an "Applicant" is required to make a certificate request before 
being, well, an "Applicant".

 

If they are required to make a request, then naturally, it follows that your 
so-called hoop-jumping is necessary, since there is a minimum definition of 
what constitutes a certificate request.

If they are not required to make a request, then naturally, the scenario I 
described is the logical extreme, in which the CA can validate 'everything but 
the application'. To further add to the extreme, it might be possible for the 
CA to pre-generate the public key, and just call up the subscriber and say "Do 
you want a cert" - with that assent being sufficient to constitute an 
"Application"

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