Forwarding on behalf of Phil.
-------- Forwarded Message --------
Subject: Re: [cabfpub] [EXTERNAL] The purpose of the CA/B Forum
Date: Mon, 21 Oct 2019 14:21:43 -0400
From: Phillip Hallam-Baker <[email protected]>
To: Kirk Hall via Public <[email protected]>
CC: Dimitris Zacharopoulos (HARICA) <[email protected]>, Dimitris
Zacharopoulos <[email protected]>
[I am not able to send to the list, this may be forwarded should you choose]
As one of the two people who called the meeting that led to the creation
of CABForum, I can confirm that Dimitris is correct.
There is however another much more important reason for representatives
whose companies operate root key programs to avoid making threats: The
operation of CABForum is subject to US and EU anti-trust law. This was
of course a major concern for Microsoft at the time CABForum was being
formed.
I recently had to point out to one root key program operator that they
should run a proposed internal ballot on through their internal lawyers
as they would face an obvious anti-Trust challenge if they allowed it to
go ahead.
It would probably be wise for all parties operating root programs to
note that there are storms brewing in Washington as well as Brussels.
And not just in one party.
On Mon, Oct 21, 2019 at 1:09 PM Kirk Hall via Public
<[email protected] <mailto:[email protected]>> wrote:
+1 Dimitris. As the immediate past Chair of the Forum and someone
involved in creating the Forum in 2005, your analysis below is correct.
*From:* Public <[email protected]
<mailto:[email protected]>> *On Behalf Of *Dimitris
Zacharopoulos via Public
*Sent:* Monday, October 21, 2019 8:54 AM
*To:* [email protected] <mailto:[email protected]>
*Subject:* [EXTERNAL][cabfpub] The purpose of the CA/B Forum
*WARNING:* This email originated outside of Entrust Datacard.
*DO NOT CLICK* links or attachments unless you trust the sender and
know the content is safe.
------------------------------------------------------------------------
Dear CA/B Forum Members,
Recent posts [1], [2] were brought to my attention with a statement
from a representative of a Certificate Consumer Member who believes
that the role of the Forum is the following:
"The Forum provides a venue to ensure Browsers do not place
conflicting requirements on CAs that voluntarily participate within
the browsers root programs, by facilitating discussion and feedback.
This allows interoperability among the Web PKI space, which refers
to the set of CAs within browsers, and thus allows easier
interoperability within browsers. Prior to the Forum, it was much
easier to see this reflected in the private arrangements between CAs
and browsers. If different browsers had different requirements, CAs
would have to act as the intermediary to identify and communicate
those conflicts. Similarly, browsers had to spend significant effort
working to communicate with all of the CAs in their programs, often
repeatedly answering similar questions. By arranging a common
mailing list, and periodic meetings, those barriers to communication
can be reduced.
That is the sole and only purpose of the Forum. Any other suggestion
is ahistorical and not reflected in the past or present activities."
We should not interpret silence as consent for such statements that
can create misunderstandings. I put a lot of thought before posting
this message because I represent a CA but I was also voted as Chair
to ensure the Bylaws are followed. I personally don’t agree with
that view of the purpose of the Forum (or the statement that any
other suggestion is ahistorical), and I think other members disagree
as well. As Chair of the Forum, I feel obligated to share some
thoughts and my perspective about the purpose of the Forum.
When I first learned about the CA/B Forum and started receiving the
public list emails, I was thrilled with the level of engagement,
participation and contributions of industry leaders in the
publicly-trusted certificate sector. Industry leaders, that made
SSL/TLS and Code Signing Certificates known and usable around the
Globe in order to secure communications and code execution, were
voluntarily contributing with their valuable technical and
operational experience. When critical incidents occurred that
affected a large part of the webPKI, industry leaders freely shared
their internal security policies/practices, so that others could
publicly evaluate and use them. When it was decided for Domain
Validation methods to be disclosed, Certificate Issuers disclosed
their methods and the less secure methods were identified and
removed. Some of the Forum's popular projects, such as the EV
Guidelines and the Network Security Requirements, were driven by
Certificate Issuers and were not directly linked to Certificate
Consumer's Root program policies; they are now required by Root
programs. This industry continues to improve Guidelines and overall
security by continuously raising the security bar. It is natural for
Certificate Consumers to lead and push for stricter rules but
Certificate Issuers also participate in these discussions and
contribute with ideas. These contributions are not made "to make
Browsers happy" but to improve the overall security of the ecosystem.
Mistakes happened, CAs were distrusted but that has nothing to do
with the CA/B Forum. We are not here at the Forum to judge how CAs
complied or not to the Guidelines or how strict or not the Browser
decisions were. In my understanding these are out of CA/B Forum
scope discussions. To my eyes, every contribution to the Forum is
done in good faith, reviewed by some of the world's most talented
and competent people I know and they are accepted into the work
product of the Forum, which is our Guidelines. It is also very clear
that our Guidelines need continuous improvements and it is very
possible that some requirements are mis-interpretated. We are here
to remove ambiguities and make these requirements as clear as possible.
I have no doubt that the CA/B Forum serves the "undocumented"
purpose of aligning requirements between Certificate Consumer
Policies, although it is not stated in the Forum's Bylaws. Perhaps
this is how things started with the Forum. I don't know, I wasn't
there :) But I believe things have evolved. I strongly believe that
the CA/B Forum is an earnest effort by the publicly-trusted
certificate industry to *self-regulate* in the absence of other
National or International regulatory Authorities. These efforts to
self-regulate exceed the purpose for Root Programs to align. After
all, if that was the sole and only purpose, it might as well have
been the "Browser Forum" where Browsers meet, set the common rules
and then dictate CAs to follow these rules. I believe the Forum is
more than that.
It is fortunate that we are given the opportunity to take a step
back and re-check why we are all here. I can only quote from the
Bylaws (emphasis mine):
"1.1 Purpose of the Forum
The Certification Authority Browser Forum (CA/Browser Forum) is a
voluntary gathering of leading Certificate Issuers and vendors of
Internet browser software and other applications that use
certificates (Certificate Consumers).
Members of the CA/Browser Forum have worked closely together in
defining the guidelines and means of *implementation for best
practices as a way of providing a heightened security for Internet
transactions and creating a more intuitive method of displaying
secure sites to Internet users*."
I read this purpose as an "unofficial" agreement between Certificate
Issuers and Certificate Consumers to improve security for internet
transactions AND to create a more intuitive method of displaying
secure sites to internet users. I have only been involved in the
Forum for the last couple of years and although I see a lot of
effort to improve security policies/practicies (as demonstrated in
all the updates of the BRs, EVGs, NetSec guidelines), there are no
documented efforts for the purpose of creating a more intuitive
method of displaying secure sites to Internet users.
Setting this aside, I believe we either need to agree that the
purpose of the Forum, as described in the Bylaws, is incorrect and
update the Bylaws, or to take a step back and consider all that the
Forum has accomplished over the last years with the Contributions of
its Members, Associate Members, Interested Parties, even
non-Members, and work collaboratively, in good faith to make further
progress.
Looking back at my notes during a presentation at the F2F 46 meeting
in Cupertino, I mentioned:
"Forum members should exercise their participation in a neutral way
as much as possible. We are here to create and improve guidelines
and we need to be able to do that with more participation and
consensus. Some members feel “exposed” during Forum discussions. All
members must have a more “neutral” behavior in the CA/B Forum
discussions around guidelines. We welcome more contributions from
Certificate Issuers in order to understand real cases and improve
overall security". I do not recall hearing any objections to this
statement, but that was perhaps because members were very polite :-)
I'm afraid this cannot be achieved if Certificate Consumer Members
continuously bring their "guns" (i.e. Root Program Requirements) in
CA/B Forum discussions. I would expect these "guns" to be displayed
and used in the independent Root Program venues and not the CA/B Forum.
I would personally feel very disappointed (as the CA/B Forum Chair)
if we were to re-purpose of the Forum to match the statement at the
beginning of this email. In any case, I would like to give the
opportunity for members to publicly express their opinion about the
purpose of the Forum and especially the Server Certificate Working
Group. I also understand and respect if some Members are reluctant
to publicly state their opinion.
Dimitris.
CA/B Forum and Server Certificate Working Group Chair
[1] https://cabforum.org/pipermail/validation/2019-September/001326.html
[2]
https://cabforum.org/pipermail/servercert-wg/2019-October/001171.html
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