PKIoverheid votes YES.

We’ve been following the discussion as it has unfolded. The definition of 
current methods 3.2.2.4.1 and 3.2.2.4.5, as currently worded in the BR, we have 
to agree,  leaves much room for interpretation. However, we might be able to 
improve these methods, a process that will require time.

In this discussion there are CAs and browsers on the one side who are 
(possibly) proposing a more radical solution of termination of said validation 
methods per March 1 (enforced through browser program requirements), there is 
ballot 218 which proposes abolition of 3.2.2.4.1 and 3.2.2.4.5 per August 1, 
and there are parties who want to keep current methods in place, at least long 
enough for new and improved versions to be developed and deployed. The last 
option has the danger that a working group effort could go on for months and 
months without much progress, while the current methods stay in place. This 
ballot, with a firm deadline of August 1, puts a fixed end date on the current 
methods .1 and .5. We welcome possible working group discussions about a new or 
improved domain validation methods (possibly included in the broader 
discussion, see Dimitris’ response below) and is, in our view, this ballot is 
the best approach forward. It’s a combination of an achievable timeline for CAs 
to move away from 3.2.2.4.1 and 3.2.2.4.5 while also including a final date by 
which CAs must have changed to a different method.

Kind regards,

Jochem van den Berge

Logius PKIoverheid
Public Key Infrastructure for the Dutch government
........................................................................
Logius
Ministry of the Interior and Kingdom Relations (BZK)
Wilhelmina van Pruisenweg 52 | 2595 AN | The Hague
PO Box 96810 | 2509 JE | The Hague
........................................................................
[email protected]<mailto:[email protected]>
http://www.logius.nl



Van: Public [mailto:[email protected]] Namens Dimitris Zacharopoulos 
via Public
Verzonden: donderdag 1 februari 2018 15:35
Aan: [email protected]<mailto:[email protected]>
Onderwerp: Re: [cabfpub] Voting begins: Ballot 218 version 2


All currently approved Domain Validation methods provide some level of 
assurance which is not easily quantifiable without calculating the risks 
(vulnerabilities, threats) of each method. If we had a methodology to quantify 
the assurance level of each method, we would be able to compare them.

The discussion around methods 3.2.2.4.1 (1 and 2)  and 3.2.2.4.5 demonstrated 
that these methods have lower assurance levels than the other methods, without 
providing conclusive evidence to support ultimate failure of #1 and #5. If we 
had that, probably all validations performed with methods #1 and #5 would have 
to be invalidated and re-done using other methods. This means that the forum 
considered these methods "acceptable" so far which means they provided a 
"reasonable" assurance level. The bar has been raised, but not in a measurable 
way. Intuitively, these methods were proved to be the "weakest" among the other 
methods, even though there are known vulnerabilities for almost all of them 
(including DNS/routes hijacking, etc). The validation working group should 
discuss more about the threats of each method (and how to formalize the level 
of assurance) in case a similar discussion about the other methods is brought 
forward.

HARICA votes "abstain" to ballot 218.


Dimitris.

On 29/1/2018 11:51 μμ, Tim Hollebeek via Public wrote:

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 3.2.2.4 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 
3.2.2.4, 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 3.2.2.4.1, 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 3.2.2.4.5, 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 3.2.2.4.10, add following two new subsections:
“3.2.2.4.11 Any Other Method

This method has been retired and MUST NOT be used.

3.2.2.4.12 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 3.2.2.4.1 or Section 3.2.2.4.5 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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