“Certificate-based authentication can be used as part of Multifactor 
Authentication only if the private key is stored in a Secure Key Storage 
Using a ‘SKSD’ doesn’t mean a 2 factors authentication.
It only guaranties that the private key cannot be duplicated and/or stolen.
When the SKSD is for example a smartcard under the sole control of a human 
being that keeps private the activation secret, then we have 2FA.
When the SKSD is an HSM, most of the time the HSM is accessed programmatically 
with a passphrase that is stored in the ‘memories’ of the server (i.e. RAM, 
Database, INI file…) or with a software certificate ;-).
If we take Diginotar as an example, the hacker found the activation secret of 
the HSM (thales one) in the RAM of the server and then gain access to the 
authenticated PKCS11 API in order to issue certificates.

So we have to make a clear distinction when this is a human being that uses a 
GUI to validate a certificate issuance, and when systems communicate inside a 
secure zone using authenticated channels.

Best regards
Franck Leroy

De : Public [mailto:public-boun...@cabforum.org] De la part de Tim Hollebeek 
via Public
Envoyé : mercredi 28 mars 2018 21:39
À : Ryan Sleevi <sle...@google.com>; CA/Browser Forum Public Discussion List 
Objet : Re: [cabfpub] Ballot 221: Two-Factor Authentication and Password 

Thank you.

From: Ryan Sleevi [mailto:sle...@google.com]
Sent: Wednesday, March 28, 2018 3:29 PM
To: Tim Hollebeek 
<tim.holleb...@digicert.com<mailto:tim.holleb...@digicert.com>>; CA/Browser 
Forum Public Discussion List <public@cabforum.org<mailto:public@cabforum.org>>
Subject: Re: [cabfpub] Ballot 221: Two-Factor Authentication and Password 

Note, the redline doc doesn't quite align with this ballot text - look for 
"Multi-Ffactor" in the doc :)

On Wed, Mar 28, 2018 at 3:25 PM, Tim Hollebeek via Public 
<public@cabforum.org<mailto:public@cabforum.org>> wrote:

Ballot 221: Two-Factor Authentication and Password Improvements

Purpose of Ballot: The Network Security Working Group met a number of times to
improve the Network Security Guidelines requirements around authentication,
specifically by requiring two-factor authentication, and improving the password
requirements in line with more recent NIST guidelines.

While CAs are encouraged to improve their password requirements as soon as
possible, a two year grace period is being given to allow organizations to
develop and implement policies to implement the improved requirements, 
since some organizations may have to simultaneously comply with other
compliance frameworks that have not been updated yet and are based on older NIST
guidance about passwords.

The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.


This ballot modifies the “Network and Certificate System Security Requirements”
as follows, based upon Version 1.1:

In the definitions, add a definition for Multifactor Authentication:

"Multi-Factor Authentication: An authentication mechanism consisting of two or
more of the following independent categories of credentials (i.e. factors) to
verify the user’s identity for a login or other transaction: something you know
(knowledge factor), something you have (possession factor), and something you
are (inherence factor).  Each factor must be independent.  Certificate-based
authentication can be used as part of Multifactor Authentication only if the
private key is stored in a Secure Key Storage Device."

Add a definition for Secure Key Storage Device:

"Secure Key Storage Device: A device certified as meeting at least FIPS 140-2
level 2 overall, level 3 physical, or Common Criteria (EAL 4+)."

In section 1.j., capitalize Multi-Factor Authentication, and strike the
parenthetical reference to subsection 2.n.(ii).

In section 2.f., add "(for accountability purposes, group accounts or shared
role credentials SHALL NOT be used)" after "authenticate to Certificate 

Change section 2.g. to read:

"g. If an authentication control used by a Trusted Role is a username and 
    then, where technically feasible, implement the following controls:
  i.           For accounts that are accessible only within Secure Zones or 
High Security
               Zones, require that passwords have at least twelve (12) 
  ii.          For accounts that are accessible from outside a Secure Zone or 
High Security
               Zone, require Multi-Factor Authentication, with passwords that 
have at least
               eight (8) characters and are not be one of the user's previous 
four (4)
               passwords; and implement account lockout for failed access 
attempts in
               accordance with subsection k;
  iii.        When developing password policies, CAs SHOULD take into account 
the password
               guidance in NIST 800-63B Appendix A.
  iv.         If passwords are required to be changed periodically, that period 
               at least two years.  Effective April 1, 2020, if passwords are 
required to
               be changed periodically, that period SHALL be at least two 

In section 2.h., change "Require" to "Have a policy that requires"

In section 2.i., change "Configure" to "Have a procedure to configure"

Change section 2.k. to read:

"k. Lockout account access to Certificate Systems after no more than five (5) 
failed access attempts, provided that this security measure:
  i.           is supported by the Certificate System,
  ii.          Cannot be leveraged for a denial of service attack, and
  iii.        does not weaken the security of this authentication control;"

Change section 2.n. to read:

"Enforce Multi-Factor Authentication for all Trusted Role accounts on 
Systems (including those approving the issuance of a Certificate, which equally
applies to Delegated Third Parties) that are accessible from outside a Secure 
or High Security Zone; and”


The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: 2018-03-28  15:30:00 EDT

End Time: after 2018-04-04 15:30:00 EDT

Vote for approval (7 days)

Start Time: TBD

End Time: TBD

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