Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Erwann Abalea]

Bonjour,

Le lundi 9 janvier 2017 18:02:57 UTC+1, Jeremy Rowley a écrit :
> Not many websites, but all of the Belgium ID cards would end up being
> revoked. 

Not exactly. The "Belgium Root CAx" CA certificates issued by Cybertrust would 
be revoked, but since these CAs also have self-signed certificates, Belgium ID 
cards will still have a valid chain up to these self-signed "Belgium Root CAx" 
certificates.

> Although Belgium is only issuing client certs, the issuing CA is not
> technically constrained, meaning a BR, Network security, and standard
> WebTrust audit is required. We are currently waiting for the results of the
> audit report.

And maybe the opinion report from a Qualified Auditor regarding the private key 
generation of these subordinate CAs.
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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Ben Wilson]

I'll go through those in the next day or so and fix the CPS and  audit settings.

Ben Wilson, JD, CISA, CISSP
DigiCert VP Compliance


-Original Message-
From: dev-security-policy 
[mailto:dev-security-policy-bounces+ben=digicert@lists.mozilla.org] On 
Behalf Of Rob Stradling
Sent: Monday, January 9, 2017 10:02 AM
To: Jeremy Rowley ; 
mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Update on transition of the Verizon roots and issuance of SHA1 
certificates

On 09/01/17 16:35, Jeremy Rowley wrote:
> Hi Rob - thanks for following up.
>
> The Belgium root was granted an extension by the browsers until
> January 15th to complete the audit and January 31st to submit the
> audit report. We are still told they are hosted by Verizon and,
> considering the audit progress, I have no reason to doubt this.

Jeremy, thanks for that update.

Given that you're still anticipating not needing to revoke the Belgian 
government CAs...

Please could you also confirm whether or not the "Same as Parent"
tickboxes have been set correctly?

Thanks.

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online

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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Jeremy Rowley]

It probably should not be same as parent. Ben will update it.

-Original Message-
From: Rob Stradling [mailto:rob.stradl...@comodo.com] 
Sent: Monday, January 9, 2017 10:02 AM
To: Jeremy Rowley ;
mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Update on transition of the Verizon roots and issuance of SHA1
certificates

On 09/01/17 16:35, Jeremy Rowley wrote:
> Hi Rob - thanks for following up.
>
> The Belgium root was granted an extension by the browsers until 
> January 15th to complete the audit and January 31st to submit the 
> audit report. We are still told they are hosted by Verizon and, 
> considering the audit progress, I have no reason to doubt this.

Jeremy, thanks for that update.

Given that you're still anticipating not needing to revoke the Belgian
government CAs...

Please could you also confirm whether or not the "Same as Parent" 
tickboxes have been set correctly?

Thanks.

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online



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Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Rob Stradling]

On 09/01/17 16:35, Jeremy Rowley wrote:

Hi Rob - thanks for following up.

The Belgium root was granted an extension by the browsers until January 15th
to complete the audit and January 31st to submit the audit report. We are
still told they are hosted by Verizon and, considering the audit progress, I
have no reason to doubt this.


Jeremy, thanks for that update.

Given that you're still anticipating not needing to revoke the Belgian 
government CAs...


Please could you also confirm whether or not the "Same as Parent" 
tickboxes have been set correctly?


Thanks.

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online

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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Jeremy Rowley]

Not many websites, but all of the Belgium ID cards would end up being
revoked. 

Although Belgium is only issuing client certs, the issuing CA is not
technically constrained, meaning a BR, Network security, and standard
WebTrust audit is required. We are currently waiting for the results of the
audit report.

Jeremy

-Original Message-
From: dev-security-policy
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert.com@lists.mozilla
.org] On Behalf Of Kurt Roeckx
Sent: Monday, January 9, 2017 9:54 AM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Update on transition of the Verizon roots and issuance of SHA1
certificates

On 2017-01-09 17:28, Rob Stradling wrote:
> On 03/11/16 19:34, Jeremy Rowley wrote:
> 
>
> Hi Jeremy.
>
>> 7.   The Belgium government is our biggest challenge in migrating
>> Verizon customers. With over 20 issuing CAs, Belgium has the largest 
>> outstanding non-compliant infrastructure. The operators have also 
>> claimed that revoking their issuing CAs is illegal (in Belgium). The 
>> government is using the issuing CA for creating personal 
>> identification (e-ID) cards throughout the country. The Belgium 
>> government has dictated that they set the rules, not us. Although the 
>> Belgium government does not have an audit yet, Verizon has 
>> represented that the issuing CAs are hosted in the Verizon 
>> infrastructure and are potentially covered by the Verizon audit.
>
> I've noticed that some of the Belgian government CAs have been 
> disclosed to the CCADB with the CP/CPS and Audit fields marked as 
> "Same as Parent", whereas the CP/CPS and Audit fields for the rest of 
> those CAs have not yet been filled in.

Note that the Belgium root CA's information is available at:
http://repository.eid.belgium.be/index.php?lang=en

As far as I know, most of the certificates are for (client) authentication
and signatures as used by the government itself and some websites that make
use of it. Those should already be set up to trust that root for client
authentication. I think I also found some websites, but most actually use a
different CA. So it seems unlikely that many public websites would get
broken by revoking it.


Kurt

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Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Kurt Roeckx]

On 2017-01-09 17:28, Rob Stradling wrote:

On 03/11/16 19:34, Jeremy Rowley wrote:


Hi Jeremy.


7.   The Belgium government is our biggest challenge in migrating
Verizon customers. With over 20 issuing CAs, Belgium has the largest
outstanding non-compliant infrastructure. The operators have also
claimed that revoking their issuing CAs is illegal (in Belgium). The
government is using the issuing CA for creating personal
identification (e-ID) cards throughout the country. The Belgium
government has dictated that they set the rules, not us. Although the
Belgium government does not have an audit yet, Verizon has represented
that the issuing CAs are hosted in the Verizon infrastructure and are
potentially covered by the Verizon audit.


I've noticed that some of the Belgian government CAs have been disclosed
to the CCADB with the CP/CPS and Audit fields marked as "Same as
Parent", whereas the CP/CPS and Audit fields for the rest of those CAs
have not yet been filled in.


Note that the Belgium root CA's information is available at:
http://repository.eid.belgium.be/index.php?lang=en

As far as I know, most of the certificates are for (client) 
authentication and signatures as used by the government itself and some 
websites that make use of it. Those should already be set up to trust 
that root for client authentication. I think I also found some websites, 
but most actually use a different CA. So it seems unlikely that many 
public websites would get broken by revoking it.



Kurt

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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Jeremy Rowley]

Hi Rob - thanks for following up. 

The Belgium root was granted an extension by the browsers until January 15th
to complete the audit and January 31st to submit the audit report. We are
still told they are hosted by Verizon and, considering the audit progress, I
have no reason to doubt this.

-Original Message-
From: Rob Stradling [mailto:rob.stradl...@comodo.com] 
Sent: Monday, January 9, 2017 9:28 AM
To: Jeremy Rowley ;
mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Update on transition of the Verizon roots and issuance of SHA1
certificates

On 03/11/16 19:34, Jeremy Rowley wrote:


Hi Jeremy.

> 7.   The Belgium government is our biggest challenge in migrating
Verizon customers. With over 20 issuing CAs, Belgium has the largest
outstanding non-compliant infrastructure. The operators have also claimed
that revoking their issuing CAs is illegal (in Belgium). The government is
using the issuing CA for creating personal identification (e-ID) cards
throughout the country. The Belgium government has dictated that they set
the rules, not us. Although the Belgium government does not have an audit
yet, Verizon has represented that the issuing CAs are hosted in the Verizon
infrastructure and are potentially covered by the Verizon audit.

I've noticed that some of the Belgian government CAs have been disclosed to
the CCADB with the CP/CPS and Audit fields marked as "Same as Parent",
whereas the CP/CPS and Audit fields for the rest of those CAs have not yet
been filled in.

If it's true that all of "the issuing CAs are hosted in the Verizon
infrastructure and are potentially covered by the Verizon audit", then it
would seem reasonable to expect to see the CP/CPS and Audit details for all
of the Belgian government CAs set identically.  Right?

Using the data on crt.sh (from which https://crt.sh/mozilla-disclosures
is produced), I've summarized the current Belgian government CA disclosures
in this spreadsheet:
https://docs.google.com/spreadsheets/d/1K4DEjqKvC5r_aiUGDYvbJBPVSOm8E6MO6RJQ
oj9zbrY/edit?usp=sharing

Were the "Same as Parent" tickboxes ticked correctly, or in error?

> We've asked Verizon to provide an updated audit report showing coverage of
the Belgium issuing CAs by December 1, 2016. If the report is not delivered
by December 1, 2016, we plan to immediately revoke the issuing CAs.

I note that you did not "immediately revoke" the issuing CAs on December 1,
2016.  Does this mean that Verizon did provide "an updated audit report
showing coverage of the Belgium issuing CAs" to DigiCert?

> If, for whatever reason, we are unable to revoke the issuing CAs at that
time, we would certainly not object to the browsers distrusting the issuing
CAs issued to Belgium.

Are you able to complete the Belgian government CA disclosures yet (either
by revoking the issuing CAs or by updating the CP/CPS and Audit details as
appropriate)?

Thanks.

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online



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Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Rob Stradling]

On 03/11/16 19:34, Jeremy Rowley wrote:


Hi Jeremy.


7.   The Belgium government is our biggest challenge in migrating Verizon 
customers. With over 20 issuing CAs, Belgium has the largest outstanding 
non-compliant infrastructure. The operators have also claimed that revoking 
their issuing CAs is illegal (in Belgium). The government is using the issuing 
CA for creating personal identification (e-ID) cards throughout the country. 
The Belgium government has dictated that they set the rules, not us. Although 
the Belgium government does not have an audit yet, Verizon has represented that 
the issuing CAs are hosted in the Verizon infrastructure and are potentially 
covered by the Verizon audit.


I've noticed that some of the Belgian government CAs have been disclosed 
to the CCADB with the CP/CPS and Audit fields marked as "Same as 
Parent", whereas the CP/CPS and Audit fields for the rest of those CAs 
have not yet been filled in.


If it's true that all of "the issuing CAs are hosted in the Verizon 
infrastructure and are potentially covered by the Verizon audit", then 
it would seem reasonable to expect to see the CP/CPS and Audit details 
for all of the Belgian government CAs set identically.  Right?


Using the data on crt.sh (from which https://crt.sh/mozilla-disclosures 
is produced), I've summarized the current Belgian government CA 
disclosures in this spreadsheet:

https://docs.google.com/spreadsheets/d/1K4DEjqKvC5r_aiUGDYvbJBPVSOm8E6MO6RJQoj9zbrY/edit?usp=sharing

Were the "Same as Parent" tickboxes ticked correctly, or in error?


We've asked Verizon to provide an updated audit report showing coverage of the 
Belgium issuing CAs by December 1, 2016. If the report is not delivered by 
December 1, 2016, we plan to immediately revoke the issuing CAs.


I note that you did not "immediately revoke" the issuing CAs on December 
1, 2016.  Does this mean that Verizon did provide "an updated audit 
report showing coverage of the Belgium issuing CAs" to DigiCert?



If, for whatever reason, we are unable to revoke the issuing CAs at that time, 
we would certainly not object to the browsers distrusting the issuing CAs 
issued to Belgium.


Are you able to complete the Belgian government CA disclosures yet 
(either by revoking the issuing CAs or by updating the CP/CPS and Audit 
details as appropriate)?


Thanks.

--
Rob Stradling
Senior Research & Development Scientist
COMODO - Creating Trust Online

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Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Dimitris Zacharopoulos]

This looks like a very accurate representation of the data protection European 
regulations. I have the same view. 

Not so easy to implement but if it is implemented correctly, I think very few 
people will disagree with the essence of this regulation. 

Dimitris. 

--
Sent from my mobile device. Pls excuse brevity and typos

> On 5 Nov 2016, at 11:50, Nick Lamb  wrote:
> 
>> On Friday, 4 November 2016 19:37:07 UTC, Jeremy Rowley  wrote:
>> We also like the public disclosures CT requires as its been essential in 
>> identifying issuing CAs and non-compliances.  That's probably not a surprise 
>> as we've always strongly supported CT. I do see the need for name redaction 
>> though as lots of the certificates are issued to individuals, and the 
>> European government freaks out whenever there is the potential disclosure of 
>> PII.
> 
> Unlike with DNS names / IP addresses in the Web PKI, I could still be 
> persuaded that redacting personal information about individual human 
> subscribers would make sense.
> 
> Nevertheless I think it's valuable to understand that European regulations in 
> this area ("Data Protection" is the usual English term) are not intended to 
> altogether prohibit the disclosure of PII. The regulations are instead 
> focused on ensuring that subjects know what is held about them, that they're 
> told how it will be used and why, that the data used is adequate yet not 
> excessive for that purpose, and that they can get any mistakes fixed.
> 
> So Data Protection could permit unredacted CT logging if it served some 
> legitimate purpose, particularly one that's in the subject's best interest 
> such as deterring identity fraud or protecting the integrity of the 
> certificate ecosystem they're using, and if subscribers were told about this 
> before they request the certificate.
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Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Nick Lamb]

On Friday, 4 November 2016 19:37:07 UTC, Jeremy Rowley  wrote:
> We also like the public disclosures CT requires as its been essential in 
> identifying issuing CAs and non-compliances.  That's probably not a surprise 
> as we've always strongly supported CT. I do see the need for name redaction 
> though as lots of the certificates are issued to individuals, and the 
> European government freaks out whenever there is the potential disclosure of 
> PII.

Unlike with DNS names / IP addresses in the Web PKI, I could still be persuaded 
that redacting personal information about individual human subscribers would 
make sense.

Nevertheless I think it's valuable to understand that European regulations in 
this area ("Data Protection" is the usual English term) are not intended to 
altogether prohibit the disclosure of PII. The regulations are instead focused 
on ensuring that subjects know what is held about them, that they're told how 
it will be used and why, that the data used is adequate yet not excessive for 
that purpose, and that they can get any mistakes fixed.

So Data Protection could permit unredacted CT logging if it served some 
legitimate purpose, particularly one that's in the subject's best interest such 
as deterring identity fraud or protecting the integrity of the certificate 
ecosystem they're using, and if subscribers were told about this before they 
request the certificate.
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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Jeremy Rowley]

Thanks Peter for the questions.  The answers are listed below:

First, a couple of questions about DigiCert itself.  The press release at 
https://thomabravo.com/2015/10/22/thoma-bravo-completes-acquisition-of-majority-stake-in-digicert/
says that Thoma Bravo acquired a majority stake in DigiCert in October 2015.  
Looking at the current portfolio 
(https://thomabravo.com/portfolio/all/current/), I don't see any other CAs, but 
can you confirm that (a) they still own a majority & controlling share of 
DigiCert and (b) that Thoma Bravo does not own a majority or controlling share 
(directly or indirectly) of any other CA?


[JR] Yes - Thoma Bravo owns a controlling interest in DigiCert. However, I 
can't say exactly which companies are owned by Thoma Bravo. That information 
isn't shared with us other than as disclosed publicly on their website. I do 
not think they own another CA though.

What is the relationship between Cyber Secure Asia
(https://www.cybersecureasia.com/about-cyber-secure-asia-csa/newsroom)
and DigiCert?  Are they a subsidiary, a subordinate CA, a reseller or something 
else?  It is hard to tell, as they talk about DigiCert all over their site but 
also say something about being a subsidiary of CyberTrust Japan (which might be 
part of DigiCert?)

[JR] They are a reseller. They don't control an issuing CA.

> About a year ago in
> July, DigiCert closed an agreement with Verizon where DigiCert took
> ownership of three publicly-trusted Verizon root certificates. These
> certificates are the Verizon Global Root CA, the Baltimore CyberTrust
> Root CA, and the Verizon Root CA.

According to 
https://mozillacaprogram.secure.force.com/CA/IncludedCACertificateReport,
DigiCert currently has 10 roots in the Mozilla trust anchor list.
These include eight with "DigiCert Inc" in the organization name attribute, one 
with "Baltimore" in the organization name attribute, and one with "CyberTrust, 
Inc" in the organization name attribute.
The removed CA report
(https://mozillacaprogram.secure.force.com/CA/RemovedCACertificateReport)
lists one root as belonging to DigiCert.  This has "GTE Corporation"
in the organization name attribute.

[JR] We acquired this root with the transaction. The root is not publicly 
trusted and was removed from the root store prior to the acquisition.

You list three root certificates in your email.  Which of the DigiCert 
certificates in the Mozilla root reports map to the three you list?

[JR] All DigiCert roots and all issuing CAs chained to the DIgiCert root are 
owned and operated by DIgiCert. The DigiCert roots have never cross-signed 
another CA. There is a one-way trust between the Verizon roots and DigiCert 
where Verizon cross-signed for ubiquity. All of them have the potential to 
chain back to Verizon, but we usually turn this off by default.


You talk about taking ownership of three "root certificates".  Did you also 
take ownership and control of all copies of the associated private keys?  Did 
you take control of other CAs and private keys (e.g. subordinate CAs) or just 
the three listed above?

[JR] Over the last year, we took physical possession of the private keys of two 
roots. This possession was limited to the root certificates and did not include 
issuing CAs chained to the roots. The final root (the Cybertrust Global root) 
should be transferred into our infrastructure this month.  Contractually, we 
needed to keep the root in Europe for a while after the acquisition.

> After watching the
> issuance of wildcard EV certs, non-compliant subordinate CAs, and
> certs with poor profiles, we made a conscious decision to purchase
> these roots with the intention of migrating them to more complaint
> system. We felt that helping these CAs get to the point of regular
> audits and best practices would raise the quality of the entire industry.

So would just revoking them.

[JR] True, but we weren't aware of any browser plans to revoke the Verizon root 
certificates. Nothing was publicly announced, and we felt that the Baltimore 
root was essential in the ecosystem because of the companies it supports. We 
thought moving the roots into DigiCert resolve previous concerns about the 
issuance processes and lack of profile control without the browsers needing to 
take a drastic measure that would distrust several prominent certificate 
authorities.

> Unfortunately, the age of the
> roots and large number of cross-signs led to a lot of missing
> paperwork and certain issues in identifying which CAs were covered by
> audits. Prior to closing we believed there were approximately five
> technically constrained sub CAs and around 20 unconstrained sub CAs.
> Turns out there were actually more than 200, each with various levels
> of compliance. Most of these Sub CAs operated under the Baltimore Cybertrust 
> root, which was created in 2000.
> To their credit, Verizon revoked 48 of the issuing CAs prior to
> DigiCert's acquisition of the roots.

Given this huge variance, 

Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Gervase Markham]

Hi Jeremy,

Thanks for posting this. Mozilla had been concerned for some time about
the level of BR compliance of the Verizon-controlled PKI and their
seeming difficulties in bringing their many sub-CAs into compliance.
When DigiCert approached us when researching the potential acquisition,
they asked us if we were planning any immediate action against Verizon.
We told them we were concerned, but nothing immediate was planned. They
told us of their plan to take over ownership of these root hierarchies
and clean them up.

When considering what to do in issues relating to the web PKI, we are
always balancing the potential disruption to users of stopping an
activity with the risk of allowing it to continue. We could have just
un-trusted the Verizon-controlled roots, but the disruption from that
would have been significant. DigiCert's offer to improve things seemed
like a good way forward to us.

Therefore, once the purchase completed, we told DigiCert they could have
some time to bring these hierarchies into BR compliance. Jeremy's post
explains how they have been doing that, and the timeline for completing
their plan.

As a consequence of this promise, and DigiCert's generally robust
response when it happens, Mozilla does not currently intend to follow up
the fact that a number of the independently-operated sub-CAs under these
roots have issued small numbers of SHA-1 certs. That doesn't mean we
will overlook every BR or policy violation, and we expect DigiCert and
its partners to operate these roots in full compliance once the
transition is finished early next year.

This is not to say that people shouldn't give feedback on the DigiCert
plan or suggest ways to improve it. Please do.

Gerv
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RE: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Jeremy Rowley]

I'm not sure exactly what you are asking. These sub CAs are cross-signs with 
other entities. DigiCert controls the root, but not the issuing CAs. Except for 
the ones I listed, they are all WebTrust or ETSI audited so we trust them. They 
are primarily government, large corporations, and other CAs. Most are 
transferring away from DigiCert or moving to a solution where we host the 
private keys and certificates. There are some who insist on operating their own 
root and cross-sign for ubiquity. 

-Original Message-
From: dev-security-policy 
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert@lists.mozilla.org]
 On Behalf Of Han Yuwei
Sent: Thursday, November 3, 2016 6:14 PM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Update on transition of the Verizon roots and issuance of SHA1 
certificates

在 2016年11月4日星期五 UTC+8上午3:52:23，Jeremy Rowley写道：
> Resent without a signature
> 
> 
> 
> Hi everyone,
> 
> 
> 
> This email is intended to gather public and browser feedback on how we are 
> handling the transitioning Verizon's customers to DigiCert and share with 
> everyone the plan for when all non-DigiCert hosted sub CAs will be fully 
> compliant with the BRs and network security guidelines. Primarily, this 
> letter addresses when all issuing CAs previously held by Verizon will be 
> covered by an unqualified audit and how we are responding to the sub CAs that 
> issued SHA1 certificates. We are looking forward to the browser and public 
> feedback on how to handle the non-compliant cross-signs and insight on how 
> the public views our transition progress and planned completion dates.
> 
> 
> 
> Background
> 
> Prior to presenting the plan for remediation, I thought I'd share a bit about 
> our progress with migrating Verizon customers.  About a year ago in July, 
> DigiCert closed an agreement with Verizon where DigiCert took ownership of 
> three publicly-trusted Verizon root certificates. These certificates are the 
> Verizon Global Root CA, the Baltimore CyberTrust Root CA, and the Verizon 
> Root CA. There were many reasons the acquisition made sense, including 
> acquisition of a root that had cross-signed DigiCert for many years. The 
> ubiquity of the Verizon roots is wide-spread, which meant a lot of CAs like 
> to cross-sign with them. Another significant reason for the acquisition was 
> an attempt to improve the CA industry. After watching the issuance of 
> wildcard EV certs, non-compliant subordinate CAs, and certs with poor 
> profiles, we made a conscious decision to purchase these roots with the 
> intention of migrating them to more complaint system. We felt that helping 
> these CAs get to the point of regular audits and best practices would raise 
> the quality of the entire industry.
> 
> 
> 
> Prior to the acquisition, we were made aware of several potential 
> non-compliances by Verizon's customers. We worked closely with Verizon to 
> clean up many of the Sub CAs, including revoking CAs that would never be 
> compliant with the requirements and attempting to technically constrain 
> others.  Sub CAs were revoked because they either didn't have an audit, were 
> unresponsive to communication, or couldn't control their issuance. Verizon 
> was a great partner and took a very proactive approach in removing CAs that 
> were not actively working towards compliance. Unfortunately, the age of the 
> roots and large number of cross-signs led to a lot of missing paperwork and 
> certain issues in identifying which CAs were covered by audits. Prior to 
> closing we believed there were approximately five technically constrained sub 
> CAs and around 20 unconstrained sub CAs. Turns out there were actually more 
> than 200, each with various levels of compliance. Most of these Sub CAs 
> operated under the Baltimore Cybertrust root, which was created in 2000.
> 
> 
> 
> To their credit, Verizon revoked 48 of the issuing CAs prior to DigiCert's 
> acquisition of the roots. Unfortunately, this left around 150 for our small 
> team to work through. Although the endeavor was daunting, Ben Wilson and 
> others worked to gather audit reports, email customers about compliance 
> dates, monitor certificates issued, and revoke non-compliant customers. 
> Verizon was very good at assisting us in these efforts. This information is 
> now recorded in the Mozilla database and continuously updated as the 
> information changes.
> 
> 
> 
> Transition Process
> 
> After our operational acquisition of the roots (which occurred the last part 
> of September, 2015), we identified 15 expired issuing CAs, 70 revoked sub 
> CAs, 131 audited sub CAs, and 36 where the status was unknown. Since then, 
> we've revoked 25 issuing CAs and assisted others with technical constraints, 
> exodus from the Omniroot cross-signing program, or obtaining audits. Of the 
> existing sub CAs, about half remain operational and are either audited or 
> technically constrained. The other half are 

Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Peter Bowen]

On Thu, Nov 3, 2016 at 11:28 AM, Jeremy Rowley
 wrote:
> This email is intended to gather public and browser feedback on how we are
> handling the transitioning Verizon's customers to DigiCert and share with
> everyone the plan for when all non-DigiCert hosted sub CAs will be fully
> compliant with the BRs and network security guidelines. Primarily, this
> letter addresses when all issuing CAs previously held by Verizon will be
> covered by an unqualified audit and how we are responding to the sub CAs
> that issued SHA1 certificates. We are looking forward to the browser and
> public feedback on how to handle the non-compliant cross-signs and insight
> on how the public views our transition progress and planned completion
> dates.

Jeremy,

Thank you for addressing this non-compliance head on.  While it
probably would have been better to raise this when you became aware of
it, it is good that DigiCert brought this to the group proactively
rather than waiting for a discussion on "should we dump these roots".

I have a bunch of questions, through out the document.

First, a couple of questions about DigiCert itself.  The press release
at 
https://thomabravo.com/2015/10/22/thoma-bravo-completes-acquisition-of-majority-stake-in-digicert/
says that Thoma Bravo acquired a majority stake in DigiCert in October
2015.  Looking at the current portfolio
(https://thomabravo.com/portfolio/all/current/), I don't see any other
CAs, but can you confirm that (a) they still own a majority &
controlling share of DigiCert and (b) that Thoma Bravo does not own a
majority or controlling share (directly or indirectly) of any other
CA?

What is the relationship between Cyber Secure Asia
(https://www.cybersecureasia.com/about-cyber-secure-asia-csa/newsroom)
and DigiCert?  Are they a subsidiary, a subordinate CA, a reseller or
something else?  It is hard to tell, as they talk about DigiCert all
over their site but also say something about being a subsidiary of
CyberTrust Japan (which might be part of DigiCert?)

> About a year ago in
> July, DigiCert closed an agreement with Verizon where DigiCert took
> ownership of three publicly-trusted Verizon root certificates. These
> certificates are the Verizon Global Root CA, the Baltimore CyberTrust Root
> CA, and the Verizon Root CA.

According to 
https://mozillacaprogram.secure.force.com/CA/IncludedCACertificateReport,
DigiCert currently has 10 roots in the Mozilla trust anchor list.
These include eight with "DigiCert Inc" in the organization name
attribute, one with "Baltimore" in the organization name attribute,
and one with "CyberTrust, Inc" in the organization name attribute.
The removed CA report
(https://mozillacaprogram.secure.force.com/CA/RemovedCACertificateReport)
lists one root as belonging to DigiCert.  This has "GTE Corporation"
in the organization name attribute.

You list three root certificates in your email.  Which of the DigiCert
certificates in the Mozilla root reports map to the three you list?

You talk about taking ownership of three "root certificates".  Did you
also take ownership and control of all copies of the associated
private keys?  Did you take control of other CAs and private keys
(e.g. subordinate CAs) or just the three listed above?

> After watching the
> issuance of wildcard EV certs, non-compliant subordinate CAs, and certs with
> poor profiles, we made a conscious decision to purchase these roots with the
> intention of migrating them to more complaint system. We felt that helping
> these CAs get to the point of regular audits and best practices would raise
> the quality of the entire industry.

So would just revoking them.

> Unfortunately, the age of the
> roots and large number of cross-signs led to a lot of missing paperwork and
> certain issues in identifying which CAs were covered by audits. Prior to
> closing we believed there were approximately five technically constrained
> sub CAs and around 20 unconstrained sub CAs. Turns out there were actually
> more than 200, each with various levels of compliance. Most of these Sub CAs
> operated under the Baltimore Cybertrust root, which was created in 2000.
> To their credit, Verizon revoked 48 of the issuing CAs prior to DigiCert's
> acquisition of the roots.

Given this huge variance, how sure are you that you have identified
all the CA certificates issued by these roots?  Did all of the CA
certificates include zero path length constraints or are there
possibly whole trees of CAs out there that are unknown?

> After our operational acquisition of the roots (which occurred the last part
> of September, 2015), we identified 15 expired issuing CAs, 70 revoked sub
> CAs, 131 audited sub CAs, and 36 where the status was unknown. Since then,
> we've revoked 25 issuing CAs and assisted others with technical constraints,
> exodus from the Omniroot cross-signing program, or obtaining audits.

What is "Omniroot"?

How many of these are operated by DigiCert and how many are 

Re: Update on transition of the Verizon roots and issuance of SHA1 certificates

[Han Yuwei]

在 2016年11月4日星期五 UTC+8上午3:52:23，Jeremy Rowley写道：
> Resent without a signature
> 
> 
> 
> Hi everyone,
> 
> 
> 
> This email is intended to gather public and browser feedback on how we are 
> handling the transitioning Verizon's customers to DigiCert and share with 
> everyone the plan for when all non-DigiCert hosted sub CAs will be fully 
> compliant with the BRs and network security guidelines. Primarily, this 
> letter addresses when all issuing CAs previously held by Verizon will be 
> covered by an unqualified audit and how we are responding to the sub CAs that 
> issued SHA1 certificates. We are looking forward to the browser and public 
> feedback on how to handle the non-compliant cross-signs and insight on how 
> the public views our transition progress and planned completion dates.
> 
> 
> 
> Background
> 
> Prior to presenting the plan for remediation, I thought I'd share a bit about 
> our progress with migrating Verizon customers.  About a year ago in July, 
> DigiCert closed an agreement with Verizon where DigiCert took ownership of 
> three publicly-trusted Verizon root certificates. These certificates are the 
> Verizon Global Root CA, the Baltimore CyberTrust Root CA, and the Verizon 
> Root CA. There were many reasons the acquisition made sense, including 
> acquisition of a root that had cross-signed DigiCert for many years. The 
> ubiquity of the Verizon roots is wide-spread, which meant a lot of CAs like 
> to cross-sign with them. Another significant reason for the acquisition was 
> an attempt to improve the CA industry. After watching the issuance of 
> wildcard EV certs, non-compliant subordinate CAs, and certs with poor 
> profiles, we made a conscious decision to purchase these roots with the 
> intention of migrating them to more complaint system. We felt that helping 
> these CAs get to the point of regular audits and best practices would raise 
> the quality of the entire industry.
> 
> 
> 
> Prior to the acquisition, we were made aware of several potential 
> non-compliances by Verizon's customers. We worked closely with Verizon to 
> clean up many of the Sub CAs, including revoking CAs that would never be 
> compliant with the requirements and attempting to technically constrain 
> others.  Sub CAs were revoked because they either didn't have an audit, were 
> unresponsive to communication, or couldn't control their issuance. Verizon 
> was a great partner and took a very proactive approach in removing CAs that 
> were not actively working towards compliance. Unfortunately, the age of the 
> roots and large number of cross-signs led to a lot of missing paperwork and 
> certain issues in identifying which CAs were covered by audits. Prior to 
> closing we believed there were approximately five technically constrained sub 
> CAs and around 20 unconstrained sub CAs. Turns out there were actually more 
> than 200, each with various levels of compliance. Most of these Sub CAs 
> operated under the Baltimore Cybertrust root, which was created in 2000.
> 
> 
> 
> To their credit, Verizon revoked 48 of the issuing CAs prior to DigiCert's 
> acquisition of the roots. Unfortunately, this left around 150 for our small 
> team to work through. Although the endeavor was daunting, Ben Wilson and 
> others worked to gather audit reports, email customers about compliance 
> dates, monitor certificates issued, and revoke non-compliant customers. 
> Verizon was very good at assisting us in these efforts. This information is 
> now recorded in the Mozilla database and continuously updated as the 
> information changes.
> 
> 
> 
> Transition Process
> 
> After our operational acquisition of the roots (which occurred the last part 
> of September, 2015), we identified 15 expired issuing CAs, 70 revoked sub 
> CAs, 131 audited sub CAs, and 36 where the status was unknown. Since then, 
> we've revoked 25 issuing CAs and assisted others with technical constraints, 
> exodus from the Omniroot cross-signing program, or obtaining audits. Of the 
> existing sub CAs, about half remain operational and are either audited or 
> technically constrained. The other half are either winding down or have been 
> revoked. All revoked certificates were disclosed to Mozilla via Salesforce 
> and should be part of OneCRL.
> 
> 
> 
> Issuing CAs
> 
> There are only a handful of non-audited sub CAs remaining (see 
> https://crt.sh/mozilla-disclosures#disclosureincomplete). We have a plan for 
> each of them that we'd like to share with you. We welcome both browser and 
> public feedback. This is, of course, simply a proposal on how to finish the 
> transition and provide transparency into where we are at. We are certainly 
> willing to modify the plan as needed to further online security and meet the 
> requirements of the root store operators.
> 
> 
> 
> The seven companies listed below are responsible for the remaining unaudited 
> sub CAs:
> 
> 
> 
> 1.   ABB has three unaudited issuing CAs. ABB didn't