D-TRUST votes Yes on ballot 2018, version 2 As documented in our CP/CPS we currently use both methods in our current validation practice. The underlying processes are audited by an independent conformity assessment body (TÜV IT) against the specifications of the BR as well as the European regulation eIDAS. As D-TRUST issues no DV certificates, however our applied validation processes are always significantly more extensive than the sole application of validation method 184.108.40.206.1 or 220.127.116.11.5.
We will adapt our testing processes and introduce further validation methods. The conversion of the processes includes changes to manual and automated processes as implemented by us especially in our managed service platform. Of course, we aim to carry out the adjustments and to put them into operation as quickly as possible. However, we certainly need sufficient time to: - re-validate domains within our managed service that used this method well before the August 1st date, and - Implement system updates in order to enable all our managed service customers to use the newly implemented methods. We thus agree with GlobalSign that the August date is tight, but achievable. Finally we agree with the view expressed that we do need a more formal and rigorous evaluation of the risks and vulnerabilities inherent in the use of each validation method and would be happy to contribute to this. Enrico Von: Public [mailto:public-boun...@cabforum.org] Im Auftrag von Tim Hollebeek via Public Gesendet: Montag, 29. Januar 2018 22:52 An: CA/Browser Forum Public Discussion List Betreff: [cabfpub] Voting begins: Ballot 218 version 2 I'm highly skeptical that discussing this for another month will change anybody's minds. It has already been discussed for over a month, including at three validation working group meetings and once on the management call, with extensive discussion on this list as well. There have been a number of clever attempts to distract from the matter at hand. Everybody seems to agree that methods #1 and #5 as currently written are insufficient to validate certificates, and efforts to improve method #1 have all either been shown to be similarly weak, or have turned the validation method into one of the other existing validation methods. In fact, this demonstrates an obvious transition path for CAs currently using method #1: use method #2 or method #3. Since methods #1 and #5 do not sufficiently validate certificates, they should not be used, and six months should be more than enough time to cease using them. Here is the final version of the ballot, with voting times. A redlined document is attached (I encourage other proposers to post ballot redlines, even if it isn't required). -Tim ----- Ballot 218 version 2: Remove validation methods #1 and #5 ----- Purpose of Ballot: Section 18.104.22.168 says that it "defines the permitted processes and procedures for validating the Applicant's ownership or control of the domain." Most of the validation methods actually do validate ownership and control, but two do not, and can be completed solely based on an applicant's own assertions. Since these two validation methods do not meet the objectives of section 22.214.171.124, and are actively being used to avoid validating domain control or ownership, they should be removed, and the other methods that do validate domain control or ownership should be used. The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed by Ryan Sleevi of Google and Rich Smith of Comodo. -- MOTION BEGINS - This ballot modifies the "Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates" as follows, based upon Version 1.5.4: In Section 1.6.1, in the definition of "Domain Contact", after "in a DNS SOA record", add ", or as obtained through direct contact with the Domain Name Registrar" In Section 126.96.36.199.1, add text at the end: "For certificates issued on or after August 1, 2018, this method SHALL NOT be used for validation, and completed validations using this method SHALL NOT be used for the issuance of certificates." In Section 188.8.131.52.5, add text at the end: "For certificates issued on or after August 1, 2018, this method SHALL NOT be used for validation, and completed validations using this method SHALL NOT be used for the issuance of certificates." After Section 184.108.40.206.10, add following two new subsections: "220.127.116.11.11 Any Other Method This method has been retired and MUST NOT be used. 18.104.22.168.12 Validating Applicant as a Domain Contact Confirming the Applicant's control over the FQDN by validating the Applicant is the Domain Contact. This method may only be used if the CA is also the Domain Name Registrar, or an Affiliate of the Registrar, of the Base Domain Name. Note: Once the FQDN has been validated using this method, the CA MAY also issue Certificates for other FQDNs that end with all the labels of the validated FQDN. This method is suitable for validating Wildcard Domain Names." In Section 4.2.1, after the paragraph that begins "After the change to any validation method", add the following paragraph: "Validations completed using methods specified in Section 22.214.171.124.1 or Section 126.96.36.199.5 SHALL NOT be re-used on or after August 1, 2018." -- MOTION ENDS - For the purposes of section 4.2.1, the new text added to 4.2.1 from this ballot is "specifically provided in a [this] ballot." The procedure for approval of this ballot is as follows: Discussion (7+ days) Start Time: 2017-01-22 21:30:00 UTC End Time: 2017-01-29 21:50:00 UTC Vote for approval (7 days) Start Time: 2017-01-29 21:50:00 UTC End Time: 2017-02-05 21:50 UTC
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