Wayne and Ryan,

 

I received some good out-of-band suggestions so I’m passing those along.

 

Generally - though not always (e.g. zero days) - attacks are seen as 
'possible', then 'feasible' before they become 'demonstrable'; there's nothing 
stopping CAs (at their own discretion) from requiring reissuance of customer 
certs based on a possible/feasible attacks - long before the risk of the attack 
becoming demonstrable.

 

CAs adopting this methodology may stay ahead of the game (as much as one can) 
by proactively reissuing certs for keys that 'may' 
(possibly/feasibly/reasonably) be at risk of an attack‎. This provides better 
security to customers, the ecosystem, and has the large potential to 
drastically reduce the number of certs that need to be revoked and reissued 
within 5 days if this methodology becomes proven or economically feasible. 
Regardless of how CAs handle these in the possible/feasible/reasonable 
categories, drawing the line at demonstrated/proven seems like a reasonable 
statement for triggering the 5 day revocation rule.

 

How about something like this:

 

**Key Compromise**: A Private Key is said to be compromised if: a) its value 
has been disclosed to an unauthorized person, b) an unauthorized person has had 
access to the private key, or c) there exists a demonstrated or proven method 
to obtain the Private Key.

 

Doug

 

From: Public <[email protected]> On Behalf Of Doug Beattie via Public
Sent: Thursday, August 23, 2018 1:38 PM
To: Ryan Sleevi <[email protected]>
Cc: [email protected]; CABFPub <[email protected]>
Subject: Re: [cabfpub] [Servercert-wg] [EXTERNAL]Re: Ballot SC6 - Revocation 
Timeline Extension

 

Exactly, let’s try to improve the language.

 

If anyone has some better idea for how to replace this with the intended 
purpose, let’s hear it!

“A Private Key is also considered compromised if methods have been developed 
that can easily calculate it based on the Public Key (such as a Debian weak 
key, see http://wiki.debian.org/SSLkeys) or if there is clear evidence that the 
specific method used to generate the Private Key was flawed.”

 

Maybe:

“a vulnerability has been exploited to disclose private keys”

 

“there exist documented methods that can be used to easily extract and release 
Private Keys”  (we may need to define easily in terms of some measure of 
difficulty)

 

 

Doug

 

From: Ryan Sleevi <[email protected]> 
Sent: Thursday, August 23, 2018 12:29 PM
To: Doug Beattie <[email protected]>
Cc: [email protected]; Wayne Thayer <[email protected]>; CABFPub 
<[email protected]>
Subject: Re: [Servercert-wg] [EXTERNAL]Re: [cabfpub] Ballot SC6 - Revocation 
Timeline Extension

 

So I think the intent here is to capture both structural weakness and known 
weakness.

 

The framing of "has been exploited to disclose private keys" has the issue that 
it requires proof of demonstration. We saw that with Heartbleed, in which some 
CAs refused to revoke certificates until specific, individual servers were 
shown to have been compromised - even though the methodology existed to do so.

 

However, at the same time, we want to be careful with an overly broad "the 
Private Key could potentially be compromised" - because that goes the other 
way, into something extremely broad where, sure, most private keys on most 
servers are going to be vulnerable to electromagnetic emissions attacks, and so 
does that count?

 

So that's where the current approach is, or at least attempting to, thread the 
needle by balancing out with 'easily calculated' or 'clear evidence'.

 

That said, I'm all in favor of trying to provide clarity here, which is the 
intent is that if it is compromised, or easily compromised, that should be 
reasonable suspicion and call to action. I realize some CAs are going to still 
haggle over the definition of "easily", because that's not going to be a clear 
cut-and-dried answer, but maybe there's an opportunity to improve the language 
within those goals?

 

On Thu, Aug 23, 2018 at 11:54 AM Doug Beattie <[email protected] 
<mailto:[email protected]> > wrote:

Ryan,

 

Yes, I mis-spoke and said the opposite of what I had intended.  We should 
generalize this statement so it applies to the 24 hour rule.


Change this:

“ A Private Key is also considered compromised if methods have been developed 
that can easily calculate it based on the Public Key (such as a Debian weak 
key, see http://wiki.debian.org/SSLkeys) or if there is clear evidence that the 
specific method used to generate the Private Key was flawed.”

 

To something like this:

“a vulnerability has been exploited to disclose private keys”

 

Why?

-          Including examples in definitions can imply you only need to look at 
those, and 

-          listing only computational efforts and poor key quality doesn’t 
cover all the cases.  

 

I’m open to a better statement, but it should cover “all cases”.

 

 

From: Ryan Sleevi <[email protected] <mailto:[email protected]> > 
Sent: Thursday, August 23, 2018 11:44 AM
To: Doug Beattie <[email protected] 
<mailto:[email protected]> >; [email protected] 
<mailto:[email protected]> 
Cc: Wayne Thayer <[email protected] <mailto:[email protected]> >; CABFPub 
<[email protected] <mailto:[email protected]> >
Subject: Re: [Servercert-wg] [EXTERNAL]Re: [cabfpub] Ballot SC6 - Revocation 
Timeline Extension

 

Doug,

 

I'm not sure I understand - how do you see them fitting under the 5 day rule?

 

On Thu, Aug 23, 2018 at 11:40 AM Doug Beattie via Servercert-wg 
<[email protected] <mailto:[email protected]> > wrote:

Wayne,

 

I wanted to see if we we could trim down the definition of Key Compromise a bit 
more to just this:

 

**Key Compromise**: A Private Key is said to be compromised if its value has 
been disclosed to an unauthorized person or an unauthorized person has had 
access to it. 

 

I think we can remove this from your current definition because these 
situations will fall under the 5 day rule, not the 24 hour rule: 

“A Private Key is also considered compromised if methods have been developed 
that can easily calculate it based on the Public Key (such as a Debian weak 
key, see http://wiki.debian.org/SSLkeys) or if there is clear evidence that the 
specific method used to generate the Private Key was flawed.”

 

 

From: Wayne Thayer < <mailto:[email protected]> [email protected]> 
Sent: Tuesday, August 21, 2018 4:58 PM
To: Ryan Sleevi < <mailto:[email protected]> [email protected]>
Cc: Bruce Morton < <mailto:[email protected]> 
[email protected]>; CA/B Forum Server Certificate WG Public 
Discussion List < <mailto:[email protected]> 
[email protected]>; Mike Reilly (WDG) < 
<mailto:[email protected]> [email protected]>; Doug Beattie < 
<mailto:[email protected]> [email protected]>; Tim 
Hollebeek < <mailto:[email protected]> [email protected]>; 
CA/Browser Forum Public Discussion List < <mailto:[email protected]> 
[email protected]>
Subject: Re: [Servercert-wg] [EXTERNAL]Re: [cabfpub] Ballot SC6 - Revocation 
Timeline Extension

 

Thanks for the comments Mike. Based on the discussion, I would propose two 
changes:

 

1. Regarding your second point about "The technical content or format of the 
Certificate presents an unacceptable risk", my interpretation of the language 
in the context of the section is that the "given period of time" must be no 
more than 5 days, which doesn't make a lot of sense. Bruce's interpretation 
seems more reasonable but not what the current wording really means.  If this 
language only comes into effect after a deadline is set, as implied by the 
example, then any requirement to revoke can be stipulated by whomever set the 
deadline (root program or CAB Forum ballot). It follows that this reason for 
revocation (in both the Subscriber and Subordinate CA sections) is unnecessary 
and can be removed.

 

2. Regarding the third point, add the Subscriber in addition to the "entity 
reporting the Certificate Problem Report" as someone to consult when deciding 
when to revoke the certificate. I think the other clarifications you suggested 
are already covered.

 

Here are the changes I've captured from the discussion to-date:

 

 
<https://github.com/wthayer/documents/commit/2d427a74f604d635609602bed2808e5d96ee03ad>
 
https://github.com/wthayer/documents/commit/2d427a74f604d635609602bed2808e5d96ee03ad

 

I'll publish a 'version 2' of the ballot when it appears that there are no 
further concerns.

 

- Wayne

 

 

On Tue, Aug 21, 2018 at 10:08 AM Ryan Sleevi < <mailto:[email protected]> 
[email protected]> wrote:

 

On Tue, Aug 21, 2018 at 1:01 PM Bruce Morton via Servercert-wg < 
<mailto:[email protected]> [email protected]> wrote:

Per Mike’s items:

 

1.      7 days would be preferable as this would provide a “business week” for 
the CA to investigate the issue. It will also provide 2 extra days to have 
reach and discuss the issue with the Reporter and the Subscriber.

As Mike summarized correctly, Google felt and feels that 7 days is too long. We 
repeatedly asked for specific examples and details of where the additional time 
would be valuable, and to date, no CA has provided them. We had previously 
proposed that anything longer should require a mandatory public, unredacted 
incident report from the CA, and the concession to avoid such a requirement was 
to find a balance, while also ensuring that CAs were gathering and collecting 
concrete reports to provide that.

 

2.      Given the examples for unacceptable risk, I would assume that this item 
would have a deadline set in the BRs. We have done this before with 
non-registered domain name certificates. So if the certificate has not been 
revoked by the deadline, then it must be revoked immediately. As such, perhaps 
this requirement should be better defined and also moved to the 24 hour section.

3.      I do agree that the CA should work with both the Reporter and the 
Subscriber; however, please note that the investigation may mean that the 
certificate will not be revoked. Also, having a preliminary report within 24 
hours may not be feasible to have a report with substantial substance as there 
may not be time to discuss with the Subscriber. I do suggest that within 24 
hours the CA should advise the Reporter and the Subscriber that an 
investigation has started which may result in the certificate being revoked.

I don't think this is something we'd agree on. As noted above, our goal is to 
improve the transparency. There are some who've said that the best solution to 
these issues is to know what it's like by going to work for a CA. Absent 
changing employers, the next best thing is going to be to improve the 
transparency of the ecosystem, which will improve the trust overall. CAs are 
already required to conduct their activities within 24 hours - this doesn't 
relax that particular item, but allows them to make it available as a report, 
while offering greater flexibility. That seems a meaningful compromise to 
balance the need for transparency while providing CAs and Subscribers some 
degree of flexibility.

 

 

 

Thanks, Bruce.

 

From: Servercert-wg [mailto: <mailto:[email protected]> 
[email protected]] On Behalf Of Mike Reilly (GRC) via 
Servercert-wg
Sent: August 21, 2018 12:17 PM
To: Doug Beattie < <mailto:[email protected]> 
[email protected]>; CA/B Forum Server Certificate WG Public 
Discussion List < <mailto:[email protected]> 
[email protected]>; Tim Hollebeek < 
<mailto:[email protected]> [email protected]>; Wayne Thayer < 
<mailto:[email protected]> [email protected]>
Cc: CA/Browser Forum Public Discussion List < <mailto:[email protected]> 
[email protected]>
Subject: [EXTERNAL]Re: [Servercert-wg] [cabfpub] Ballot SC6 - Revocation 
Timeline Extension

 

Hi all.  Some areas of clarification requested from the Microsoft team:

 

*       I don’t remember why 5 days was chosen vs. 7 or 3 days.  I believe it 
was we felt 7 days was too long but 5 days was reasonable.  I believe we also 
considered the scenario where an incident occurs on a Friday evening of a three 
day weekend and the difficulty of the CA dealing with a subscriber who may be 
unavailable over a weekend for a non-urgent revocation requirement.  5 days 
covered that scenario without being too far past 24 hours.  3 days was felt to 
be too short and 7 days seemed too long.  Correct?
*       Regarding point 11. Will this "given period of time" means up to 5 days 
as well?  Point 11 reads: “The technical content or format of the Certificate 
presents an unacceptable risk to Application Software Suppliers or Relying 
Parties (e.g. the CA/Browser Forum might determine that a deprecated 
cryptographic/signature algorithm or key size presents an unacceptable risk and 
that such Certificates should be revoked and replaced by CAs within a given 
period of time)”
*       There is also a bit of confusion about the following statement as it is 
still governed by the 5 day requirement so we’re not sure why it’s called out 
this way.  “Within 24 hours of receiving a problem report, the CA is now 
required to report back to both the entity reporting the problem and the 
Subscriber on the CA's findings, and to work with the reporter to establish a 
date by which the CA will revoke the certificate.”  Should this be clarified to 
include both the reporter and the Subscriber included in both steps to reduce 
potential impact to relying parties.  Perhaps add more clarification in this 
statement: 

*       Report back the findings to reporter and the Subscriber within 24 hours
*       Work with the reporter and the Subscriber to revoke within 5 days

 

Thanks, Mike

 

From: Servercert-wg < <mailto:[email protected]> 
[email protected]> On Behalf Of Doug Beattie via Servercert-wg
Sent: Monday, August 20, 2018 1:43 PM
To: Tim Hollebeek < <mailto:[email protected]> 
[email protected]>; CA/B Forum Server Certificate WG Public Discussion 
List < <mailto:[email protected]> [email protected]>; Wayne 
Thayer < <mailto:[email protected]> [email protected]>
Cc: CA/Browser Forum Public Discussion List < <mailto:[email protected]> 
[email protected]>
Subject: Re: [Servercert-wg] [cabfpub] Ballot SC6 - Revocation Timeline 
Extension

 

Tim,

 

I agree that Vulnerability is different from key compromise and the actions we 
take should reflect that and I think we should try to keep 12 and 13 type 
events in the 5-day list.

 

Is our strategy to have vulnerabilities fall into the 5 day list and exploited 
vulnerabilities fall into the 24 hour list?

Key Compromise: A Private Key is said to be compromised if:

1)      its value has been disclosed to an unauthorized person

2)      an unauthorized person has had access to the private keys

3)      a vulnerability has been exploited to disclose private keys

And the remainder of the definition can be removed because those are examples 
of vulnerabilities being exploited ( Debian weak  and poor key generation).  If 
we want a list of possible vulnerabilities or bad practices, then we can put in 
an appendix.

 

I think #13 is a special case of #12 (both vulnerabilities), so I still 
recommend removing it.  Is the distribution of a private key in in a software 
package any different than the distribution of a private key in any other 
(insecure) method?  

 

Here’s what I’d recommend:

 

a) Use the new definition I listed above

 

b) change:

12. The CA is made aware of a vulnerability that exposes the Subscriber's 
Private Key to compromise; or

to

12. The CA is made aware of a vulnerability that has been exploited to disclose 
the Subscriber's Private Key; or

 

c) Delete #13

 

Doug

 

From: Servercert-wg < <mailto:[email protected]> 
[email protected]> On Behalf Of Tim Hollebeek via Servercert-wg
Sent: Monday, August 20, 2018 3:57 PM
To: Wayne Thayer < <mailto:[email protected]> [email protected]>; CA/B 
Forum Server Certificate WG Public Discussion List < 
<mailto:[email protected]> [email protected]>
Cc: CA/Browser Forum Public Discussion List < <mailto:[email protected]> 
[email protected]>
Subject: Re: [Servercert-wg] [cabfpub] Ballot SC6 - Revocation Timeline 
Extension

 

Vulnerability is different from key compromise.  Replacing all the heartbleed 
certificates within 24 hours would have been a huge fire drill.  It’s important 
to get them replaced as quickly as possible, but mandatory revocations within 
24 hours is going to make things worse, not better.

 

There are potential mitigating factors for a vulnerability.  For example, the 
technical details may not be publicly known yet, or there may be no public 
exploit available yet.  The vulnerability might not affect all OS versions, 
might be easily blocked by firewalls, and so on.  The amount of effort 
necessary to turn a vulnerability into a key compromise can vary from 
insignificant to “lots and lots”.

 

A compromised key, on the other hand, is clearly compromised.

 

-Tim

 

From: Servercert-wg < <mailto:[email protected]> 
[email protected]> On Behalf Of Wayne Thayer via Servercert-wg
Sent: Monday, August 20, 2018 12:52 PM
To: CA/B Forum Server Certificate WG Public Discussion List < 
<mailto:[email protected]> [email protected]>
Cc: CA/Browser Forum Public Discussion List < <mailto:[email protected]> 
[email protected]>
Subject: Re: [Servercert-wg] [cabfpub] Ballot SC6 - Revocation Timeline 
Extension

 

This has the potential to cause confusion, so I'd like to attempt to fix it. 
Given that a reasonable interpretation of the existing definition of key 
compromise encompasses reasons 12 and 13, but I want to leave those two reasons 
in the document for the sake of clarity as Ryan suggests, maybe I should just 
move those two up to the 24-hour section? I could also be persuaded that a 
vulnerability is different than proof of key compromise, in which case 12 could 
stay in the 5-day section and we could move "or there exists a practical 
technique by which an unauthorized person may discover its value" from the 
definition of key compromise to 12. What do others think?

 

- Wayne

 

On Mon, Aug 20, 2018 at 7:04 AM Ryan Sleevi < <mailto:[email protected]> 
[email protected]> wrote:

 

On Mon, Aug 20, 2018 at 9:17 AM Doug Beattie via Servercert-wg < 
<mailto:[email protected]> [email protected]> wrote:

We’re having a hard time determining the differences between the following:

 

The CA SHALL revoke a Certificate within 24 hours if:

3. The CA obtains evidence that the Subscriber's Private Key corresponding to 
the Public Key in the Certificate suffered a Key Compromise; or

 

and 

 

The CA SHOULD revoke a certificate within 24 hours and MUST revoke a 
Certificate within 5 days if one or more of the following occurs:

 

12. The CA is made aware of a vulnerability that exposes the Subscriber's 
Private Key to compromise; or

13. The CA is made aware that the Subscriber's Private Key is being publicly 
distributed in a software package.

 

If  “Subscriber's Private Key is being publicly distributed in a software 
package”, isn’t that the same as #3: “obtains evidence that the Subscriber's 
Private Key corresponding to the Public Key in the Certificate suffered a Key 
Compromise”? 

 

How do you see #12 in reality?  What types of vulnerabilities do you envision 
that could expose a subscribers Private Key that are not also consistent with 
#3?

 

While this is the same argument that I've made in the past, I think the goal 
here is to reduce ambiguity for those that might take a tortured reading of the 
text.

 

For example, at least one vendor 'obfuscated' the private key within their 
binary, requiring running the embedded private key through a transformation (I 
hesitate to say decryption, since the passphrase was itself fixed within the 
binary). Such a vendor might argue that the key has not been compromised until 
someone reverses the binary. This resolves that ambiguity by saying that the 
distribution within the binary itself constitutes a compromise, regardless of 
whether a passphrase is used.

 

Also, the definition of Private Key Compromise is very broad, and the scenarios 
in #12 and #13 would appear to fall into “Key Compromise” which further causes 
confusion about them.  What constitutes a “practical technique”?  If we applied 
this definition to #12 and #13, wouldn’t these all fall into the 24 hour rule?

 

Key Compromise: A Private Key is said to be compromised if its value has been 
disclosed to an unauthorized person, an unauthorized person has had access to 
it, or there exists a practical technique by which an unauthorized person may 
discover its value.  A Private Key is also considered compromised if methods 
have been developed that can easily calculate it based on the Public Key (such 
as a Debian weak key, see http://wiki.debian.org/SSLkeys 
<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwiki.debian.org%2FSSLkeys&data=02%7C01%7CMike.reilly%40microsoft.com%7Ccc86f18ac7f1436d776808d606dd9e4f%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636703946261915965&sdata=VTjxlqVQj%2F5CEUKsG10UF2UoC75AtmFi3d51%2Fj9wdZ4%3D&reserved=0>
 ) or if there is clear evidence that the specific method used to generate the 
Private Key was flawed.

 

 

Doug

 

From: Public <[email protected] <mailto:[email protected]> 
> On Behalf Of Wayne Thayer via Public
Sent: Monday, August 13, 2018 4:58 PM
To: CA/B Forum Server Certificate WG Public Discussion List 
<[email protected] <mailto:[email protected]> >
Cc: CA/Browser Forum Public Discussion List <[email protected] 
<mailto:[email protected]> >
Subject: [cabfpub] Ballot SC6 - Revocation Timeline Extension

 

This begins the formal discussion period for ballot SC6.

 

==========================================

 

Ballot SC6: Revocation Timeline Extension

 

Purpose of Ballot:

Section 4.9.1.1 of the Baseline Requirements currently requires CAs to revoke a 
Subscriber certificate within 24 hours of identifying any of 15 issues 
affecting the certificate. In cases where there is not an immediate threat of 
misuse of the certificate, this requirement can cause undue harm to a 
Subscriber that isn't capable of replacing the certificate prior to revocation. 
This ballot makes a number of improvements to the revocation rules imposed by 
the Baseline Requirements:

* Primarily, it creates a tiered timeline for revocations. The most critical 
"reasons" still require revocation within 24 hours, but for many others 24 
hours becomes a SHOULD and the CA has 5 days before they MUST revoke.

* A new "reason for revocation" was added to address the fact that there is 
currently no requirement for CAs to revoke a certificate when requested by the 
domain name registrant. After considering some more specific language that 
required CAs to follow 3.2.2.4 to validate domain control, I settled on the 
following more general "reason": "The CA obtains evidence that the validation 
of domain authorization or control for any Fully-Qualified Domain Name or IP 
address in the Certificate should not be relied upon."

* Reason #10 states "The CA determines that any of the information appearing in 
the Certificate is inaccurate or misleading;" This ballot removes "or 
misleading" because that is a subjective judgement that could effectively be 
used to justify censorship, as discussed at length in relation to the "Stripe, 
Inc of Kentucky" EV certificates.

* Current reasons #11 and #13 were removed from the section on subscriber 
certificates because they address cases where the intermediate and/or root must 
be revoked, so there isn't much sense (and some possible harm) in requiring 
revocation of all the leaf certs.

* It requires CAs to disclose their problem reporting mechanisms in a standard 
location: CPS section 1.5.2.

* Within 24 hours of receiving a problem report, the CA is now required to 
report back to both the entity reporting the problem and the Subscriber on the 
CA's findings, and to work with the reporter to establish a date by which the 
CA will revoke the certificate.

 

The following motion has been proposed by  Wayne Thayer of Mozilla and endorsed 
by Tim Hollebeek of DigiCert and Dimitris Zacharopoulos of Harica.

 

--- MOTION BEGINS ---

This ballot modifies the “Baseline Requirements for the Issuance and Management 
of Publicly-Trusted Certificates” as follows, based on Version 1.6.0:

** Modify Section 4.9.1.1 to read as follows: **

The CA SHALL revoke a Certificate within 24 hours if:

1. The Subscriber requests in writing that the CA revoke the Certificate;
2. The Subscriber notifies the CA that the original certificate request was not 
authorized and does not retroactively grant authorization;
3. The CA obtains evidence that the Subscriber's Private Key corresponding to 
the Public Key in the Certificate suffered a Key Compromise; or
4. The CA obtains evidence that the validation of domain authorization or 
control for any Fully-Qualified Domain Name or IP address in the Certificate 
should not be relied upon.

The CA SHOULD revoke a certificate within 24 hours and MUST revoke a 
Certificate within 5 days if one or more of the following occurs:

1. The Certificate no longer complies with the requirements of Sections 6.1.5 
and 6.1.6;
2. The CA obtains evidence that the Certificate was misused;
3. The CA is made aware that a Subscriber has violated one or more of its 
material obligations under the Subscriber Agreement or Terms of Use;
4. The CA is made aware of any circumstance indicating that use of a 
Fully-Qualified Domain Name or IP address in the Certificate is no longer 
legally permitted (e.g. a court or arbitrator has revoked a Domain Name 
Registrant's right to use the Domain Name, a relevant licensing or services 
agreement between the Domain Name Registrant and the Applicant has terminated, 
or the Domain Name Registrant has failed to renew the Domain Name);
5. The CA is made aware that a Wildcard Certificate has been used to 
authenticate a fraudulently misleading subordinate Fully-Qualified Domain Name;
6. The CA is made aware of a material change in the information contained in 
the Certificate;
7. The CA is made aware that the Certificate was not issued in accordance with 
these Requirements or the CA's Certificate Policy or Certification Practice 
Statement;
8. The CA determines that any of the information appearing in the Certificate 
is inaccurate;
9. The CA's right to issue Certificates under these Requirements expires or is 
revoked or terminated, unless the CA has made arrangements to continue 
maintaining the CRL/OCSP Repository;
10. Revocation is required by the CA's Certificate Policy and/or Certification 
Practice Statement;
11. The technical content or format of the Certificate presents an unacceptable 
risk to Application Software Suppliers or Relying Parties (e.g. the CA/Browser 
Forum might determine that a deprecated cryptographic/signature algorithm or 
key size presents an unacceptable risk and that such Certificates should be 
revoked and replaced by CAs within a given period of time);
12. The CA is made aware of a vulnerability that exposes the Subscriber's 
Private Key to compromise; or
13. The CA is made aware that the Subscriber's Private Key is being publicly 
distributed in a software package.

** Modify section 4.9.3 as follows: **

The CA SHALL provide a process for Subscribers to request revocation of their 
own Certificates. The process MUST be described in the CA's Certificate Policy 
or Certification Practice Statement. The CA SHALL maintain a continuous 24x7 
ability to accept and respond to revocation requests and Certificate Problem 
Reports.

The CA SHALL provide Subscribers, Relying Parties, Application Software 
Suppliers, and other third parties with clear instructions for reporting 
suspected Private Key Compromise, Certificate misuse, or other types of fraud, 
compromise, misuse, inappropriate conduct, or any other matter related to 
Certificates. The CA SHALL publicly disclose the instructions through a readily 
accessible online means and in section 1.5.2 of their CPS.

** Modify section 4.9.5 to read as follows: **

Within 24 hours after receiving a Certificate Problem Report, the CA SHALL 
investigate the facts and circumstances related to a Certificate Problem Report 
and provide a preliminary report on its findings to both the Subscriber and the 
entity who filed the Certificate Problem Report.

After reviewing the facts and circumstances, the CA SHALL work with any entity 
reporting the Certificate Problem Report or other revocation-related notice to 
establish a date when the CA will revoke the Certificate which MUST not exceed 
the time frame set forth in Section 4.9.1.1. The date selected by the CA SHOULD 
consider the following criteria:

1. The nature of the alleged problem (scope, context, severity, magnitude, risk 
of harm);
2. The consequences of revocation (direct and collateral impacts to Subscribers 
and Relying Parties);
3. The number of Certificate Problem Reports received about a particular 
Certificate or Subscriber;
4. The entity making the complaint (for example, a complaint from a law 
enforcement official that a Web site is engaged in illegal activities should 
carry more weight than a complaint from a consumer alleging that she didn't 
receive the goods she ordered); and
5. Relevant legislation.

--- MOTION ENDS ---

A comparison of the changes can be found at: 
https://github.com/cabforum/documents/compare/master...wthayer:patch-1?short_path=7f6d14a#diff-7f6d14a20e7f3beb696b45e1bf8196f2
 
<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fgithub.com%2Fcabforum%2Fdocuments%2Fcompare%2Fmaster...wthayer%3Apatch-1%3Fshort_path%3D7f6d14a%23diff-7f6d14a20e7f3beb696b45e1bf8196f2&data=02%7C01%7CMike.reilly%40microsoft.com%7Ccc86f18ac7f1436d776808d606dd9e4f%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636703946261925974&sdata=ZF1OJR2W60OJ9%2BA1c4BlDwDEQVzFc3ze2gI87AXrXow%3D&reserved=0>
 

 

The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: 2018-08-13  19:00 UTC

End Time: Not before 2018-08-20  19:00 UTC

Vote for approval (7 days)

Start Time: TBD

End Time: TBD

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