In general, I agree that producing the most complete set of data possible
is the most desirable course of action. However, I wonder how this desire
interacts with the full scale of the WebPKI.

Two years ago, Let's Encrypt had an incident
<https://bugzilla.mozilla.org/show_bug.cgi?id=1751984> which affected 100%
of our validations conducted via the TLS-ALPN-01 method. The end result was
10 zstd-compressed files, 10 megabytes each (due to Bugzilla's attachment
size limits), together containing 2.7 million crt.sh URIs. Those files
represented only one version of each certificate: usually the final
certificate, but sometimes the precertificate for those issuances where
production of the final certificate failed. The files also represented only
the certificates which were unexpired at the time that the incident was
discovered, only 18% of the total incident period.

If the list of affected certificates had included both the pre- and final
certificates, and had covered the full incident period, it would have been
a full gigabyte of compressed URLs. (10 MB per file x 10 files x 2 for both
kinds of certs x 5 to go from 18% to 100% of incident period.) And this
incident affected only a small fraction of Let's Encrypt's total issuance
volume -- if the issue had been with our HTTP-01 method over the same
incident period, the resulting list of URLs would have been nearly 20
gigabytes. Would this larger set of certificate data actually have been
useful to the community, given that they were already untrusted?

Acquiring this fuller list would have significantly increased the time
taken to conduct the investigation. Let's Encrypt prunes data about
already-expired certificates from our easily-queriable database to prevent
it from growing without bound, so the investigation would have had to start
pulling in log data, which is a much slower process for both writing and
executing the relevant queries. Would this additional investigation time,
and correspondingly slower incident response and remediation, have been
worthwhile?

It is possible that the incident period could have exceeded the audit log
retention period (currently 2 years) required by the BRs. In that case,
producing a full list of certificates would have been impossible. The
certificates themselves contain no indication of what validation method was
used for each identifier, so reconstruction from CT doesn't work. What
would be the appropriate action if producing the full list of
historically-affected certificates is not possible?

Thanks,
Aaron

On Thu, Apr 11, 2024 at 10:03 AM 'Chris Clements' via CCADB Public <
[email protected]> wrote:

> Hi Rob,
>
> Thank you for the comprehensive survey and for clearly communicating your
> findings.
>
> In response to your questions, and from the perspective of the Chrome Root
> Program:
>
>
> 1. Is a CA's incident report expected to disclose the affected
>> certificates that have already expired prior to the CA's response to the
>> incident?
>>
>
> We see disclosing the full set of affected certificates, regardless of
> whether they have expired or have been revoked, as presenting the community
> with the most complete perspective of an incident’s impact. This is our
> preferred approach.
>
>
> 2. Is a CA's incident report expected to disclose the affected
>> certificates that have already been revoked prior to the CA's response to
>> the incident?
>
>
> Yes, similar to the previous question, our preference is to collect the
> most complete perspective possible.
>
> 3. Is a CA's incident report expected to disclose both an affected
>> precertificate and its corresponding certificate?  Or just one of the pair?
>
>
> You raise an opportunity for improvement. Historically, a list of
> precertificates was considered acceptable. However, having both
> precertificates and final certificates provides a more comprehensive
> perspective, which we consider favorable.
>
> We appreciate other thoughts and perspectives.
>
> Additionally, we’ll plan to sync on these opinions with the other members
> of the CCADB Steering Committee, which could ultimately lead to an update
> of https://www.ccadb.org/cas/incident-report.
>
> Thanks again!
>
> -Chris
>
>
> On Mon, Apr 8, 2024 at 12:45 PM 'Rob Stradling' via CCADB Public <
> [email protected]> wrote:
>
>> In recent weeks, a number of CAs have filed incident reports relating to
>> mistakes made when setting critical flags in Subscriber certificate
>> extensions since the TLSBRv2 profiles came into force.  We thought it would
>> be worth performing a comprehensive survey ourselves in order to discover
>> if any similar incidents at other CAs had not yet been detected.
>>
>> I've run [1] against the primary crt.sh DB, which caused it to trawl
>> through the crt.sh ID space starting around the time TLSBRv2 went into
>> force to identify any Subscriber certificate containing any common
>> extension with its critical flag set incorrectly per §7.1.2.7.6.  I've
>> posted a report of the results at [2], which was generated using [3].
>>
>> Seven further incidents were identified.  I sent Certificate Problem
>> Reports to the two CAs whose affected PKI hierarchies are trusted by root
>> programs whose representatives are active in monitoring Bugzilla.  Both of
>> those CAs responded promptly and filed incident reports: [4] and [5].
>>
>> Having gathered this data, today I've used it to cross-check the lists of
>> affected certificates that CAs have provided with their incident reports.
>> I was surprised to find two bugs ([6] and [7]) without any attached list of
>> affected certificates.  I also observed some patterns of "omissions" in the
>> disclosed lists of affected certificates, for which I would like to call
>> upon the root program owners to clarify their expectations; noting that the
>> CCADB incident reporting requirements [8] say that each incident report's 
>> *"Appendix
>> must include a listing of the complete certificate details of all affected
>> certificates"*:
>>
>>    1. Is a CA's incident report expected to disclose the affected
>>    certificates that have already expired prior to the CA's response to the
>>    incident?
>>    2. Is a CA's incident report expected to disclose the affected
>>    certificates that have already been revoked prior to the CA's response to
>>    the incident?
>>    3. Is a CA's incident report expected to disclose both an affected
>>    precertificate and its corresponding certificate?  Or just one of the 
>> pair?
>>
>>
>>
>> [1]
>> https://gist.github.com/robstradling/6a5ecca872cf28232d90638fc2c44ed5#file-check_extension_criticality-go
>> [2]
>> https://gist.github.com/robstradling/6a5ecca872cf28232d90638fc2c44ed5#file-report-csv
>> [3]
>> https://gist.github.com/robstradling/6a5ecca872cf28232d90638fc2c44ed5#file-generate_report-sh
>> [4] https://bugzilla.mozilla.org/show_bug.cgi?id=1888060
>> [5] https://bugzilla.mozilla.org/show_bug.cgi?id=1888104
>> [6] https://bugzilla.mozilla.org/show_bug.cgi?id=1887096
>> [7] https://bugzilla.mozilla.org/show_bug.cgi?id=1883416
>> [8] https://www.ccadb.org/cas/incident-report
>>
>> --
>> Rob Stradling
>> Senior Research & Development Scientist
>> Sectigo Limited
>>
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