RE: DRAFT January 2020 CA Communication

2019-12-19 Thread Jeremy Rowley via dev-security-policy
Should anything be mentioned about the allowed algorithms? That's the largest 
change to the policy and  confirming the AlgorithmIdentifiers in each case may 
take some time.

-Original Message-
From: dev-security-policy  On 
Behalf Of Wayne Thayer via dev-security-policy
Sent: Thursday, December 19, 2019 10:10 AM
To: mozilla-dev-security-policy 
Subject: DRAFT January 2020 CA Communication

All,

I've drafted a new email and survey that I plan to send to all CAs in the 
Mozilla program in early January. it focuses on compliance with the new
(2.7) version of our Root Store Policy. I will appreciate your review and 
feedback on the draft:
https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J3waNOW

Note that two deadlines have been added to the communication:
* Action 3 specifies that CAs must agree to update their CP/CPS, if needed to 
comply, prior to April 1, 2020. This is intended to prevent responses that we 
have found unacceptable in the past, e.g. waiting for an annual audit before 
updating the CP/CPS.
* Action 5 requires CAs with failed Intermediate ALV results to publish a plan 
to correct these problems no later than Feb 15, 2020. Kathleen announced that 
we have begun validating audit letters for intermediate certificates back in 
October [1], and the requirement for audit statements to contain the SHA256 
fingerprint of each root and intermediate certificate that was in scope of the 
audit dates back to 2017. CAs should have already taken action to resolve these 
issues, so this deadline is intended to convey the need for an immediate 
response.

- Wayne

[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/M7NGwCh14DI/ZPDMRvDzBQAJ
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Re: DRAFT January 2020 CA Communication

2019-12-19 Thread Ryan Sleevi via dev-security-policy
On Thu, Dec 19, 2019 at 12:10 PM Wayne Thayer via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> All,
>
> I've drafted a new email and survey that I plan to send to all CAs in the
> Mozilla program in early January. it focuses on compliance with the new
> (2.7) version of our Root Store Policy. I will appreciate your review and
> feedback on the draft:
>
> https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J3waNOW


## ACTION 1 ##
One thing that I think came up from the past CA communications is that CAs
assert this, but then end up failing to actually implement.

Perhaps it may be worthwhile to be more explicit here about the
expectations:

"""
Read version 2.7 of Mozilla's Root Store Policy.

CAs are expected to review and abide by Version 2.7 of Mozilla's Root Store
Policy. This includes a number of changes from previous versions. CAs MUST
review this policy and ensure compliance, and CAs SHOULD carefully review
the differences from previous versions of Mozilla's Policy. These changes
have been discussed on mozilla.dev.security.policy and on GitHub. CAs that
did not participate in these discussions or that have not yet reviewed
these conversations should also review the discussions regarding these
changes, to reduce the chance of confusion or misinterpretation.

CAs are encouraged to raise any questions that they do not feel addressed
in the Policy, or which the discussions and reasoning for the changes was
not clear.
"""

There's probably a better way to word all of this, but where I'm trying to
emphasize
- The policy is the policy, and the ideal goal is that the policy stands by
itself
- That said, CAs understandably can misinterpret new policies when they use
the logic of past policies or interpretations, while someone reading the
policy fresh or which participated in the discussions about the policy
would not be confused by
- Even though CAs are required to follow m.d.s.p., the length of time for
Policy 2.7 may mean they have had turnover or knowledge drain or simply
forgot, so it's good to remind them that they can find information about
each and every change discussed here or on GitHub, and they're expected to
be familiar with it

I'm trying to flag the "We didn't follow the discussion and continued to
use our old interpretation" scenario, and see if there's something that can
be done to remind folks to pay attention.

## ACTION 3 ##
Would it make sense to add a third option, "All end-entity certificates
that we issue or have issued after [date] and are within..." and let folks
specify a date?

I largely mention this because it's an existing Microsoft requirement as I
understand it, and is somewhat enforced by Apple (at least for TLS) since
July, so it may be that CAs are already compliant for new certificates, but
also have unexpired old certificates that are not compliant. It may be that
the answer is supposed to be "#1", but that wasn't immediately obvious to
me when I first read.

Alternatively, it might be clearer to reword that "Beginning on 1 July,
2020, *new* end-entity ...", to emphasize that it's not that
Firefox/Mozilla will begin enforcing on 2020-07-01, but that certificates
issued on/after that date will be required to be compliant (presumably,
measured by notBefore)

## ACTION 5 ##
I'm not sure if Salesforce forms allow it, but is it possible to have
Action 5 include both a date selector and a comment field? It might make it
easier to have consistency for options 3 & 4. Like "ACTION 5 Date" and
"ACTION 5 Comments"

Of course, if it doesn't, no worries.
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Re: Incident Reporting Guidance

2019-12-19 Thread Wayne Thayer via dev-security-policy
Having received no comments on this proposal, I went ahead and added it to
the wiki [1].

- Wayne

[1] https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report

On Wed, Dec 11, 2019 at 4:45 PM Wayne Thayer  wrote:

> While thinking about different ways to solve the problem of disclosing
> missed revocation deadlines, we devised a solution for searching and
> reporting on delayed revocations separately from other incidents. We've
> begun to add a new Bugzilla "whiteboard" label to delayed revocation
> incident bugs. We can then display those incidents separately on our
> Incident Dashboard, as follows:
> https://wiki.mozilla.org/CA/Incident_Dashboard#Revocation_Delays
>
> I've come to the conclusion that Mozilla should begin to require that CAs
> submit a separate bug when a revocation deadline is missed. I dislike the
> extra overhead of creating and managing more bugs, but doing so allows us
> to provide clearer guidance to CAs, and it helps to ensure that we are
> seeking out the root causes of revocation delays when they occur, rather
> than potentially missing those learnings amongst the issue(s) that
> triggered the revocation(s). To be clear, this proposal is not intended to
> create more work or somehow punish CAs for missing revocation deadlines.
>
> This results in the following new guidance:
>
> CAs should submit a separate incident report when:
> * Mozilla policy requires that the CA revoke one or more certificates by a
> certain deadline, such as those in BR section 4.9, but that deadline is not
> met by the CA
> * In the process of researching one incident, another incident with a
> distinct root cause and/or remediation is discovered
> * After an incident bug is marked resolved, the incident reoccurs
>
> I will appreciate everyone's feedback on these proposed improvements to
> the Incident Report section [1] of our Responding to an Incident wiki page.
> If no responses are received over the next few days, I'll go ahead and make
> these changes.
>
> - Wayne
>
> [1] https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report
>
> On Thu, Nov 21, 2019 at 10:48 AM Ryan Sleevi 
> wrote:
>
>>
>>
>> On Thu, Nov 21, 2019 at 10:54 AM Wayne Thayer via dev-security-policy <
>> dev-security-policy@lists.mozilla.org> wrote:
>>
>>> During the recent CA/Browser Forum meeting, I was asked to provide better
>>> guidance on Mozilla's expectations for incident reporting. We're adding a
>>> requirement for incident reporting to the new version of our policy [1],
>>> but in this message I'm focused on the guidance provided on our wiki [2].
>>> The question was when to add information to an existing bug versus
>>> creating
>>> a new one. I'd like to propose adding the following guidance to the wiki
>>> to
>>> address this question:
>>>
>>> CAs should create a separate bug and file a new incident report when:
>>> * In the process of researching one incident another incident with a
>>> distinct root cause and/or remediation is discovered
>>> * After an incident bug is marked resolved, the incident reoccurs
>>>
>>> A third possible addition would be:
>>> * When a CA accidentally or intentionally misses a revocation deadline, a
>>> separate bug should/must be filed examining the root cause and
>>> remediation
>>> for missing the deadline
>>>
>>> I believe the argument for this is that tracking revocation issues
>>> separately will help us to focus on improving the agility of the web PKI.
>>> On the other hand, Mozilla has not generally required separate reports in
>>> the past, and doing so certainly creates more work for everyone involved.
>>> It's not clear to me that the benefit of this outweighs the cost.
>>
>>
>> Yeah, I've been thinking about this in light of the feedback Kathleen
>> offered on
>> https://groups.google.com/d/msg/mozilla.dev.security.policy/M7NGwCh14DI/jZft5ZH_AgAJ
>>
>> My primary objectives in treating it as two distinct issues are:
>> 1) Ensuring the timely remediation of the root causes of whatever
>> 'caused' the incident. In general, this should be 'sooner' than 'later'
>> 2) Ensuring transparency about when CAs are having repeat "delayed
>> revocation" issues; buried within issues themselves makes it difficult to
>> track when there are repeat offenders, but also limits visibility into
>> systemic issues that all CAs can/should be aware of when contemplating the
>> design and maintenance of their PKI
>> 3) Ensuring progress is made towards revocation, by not having bugs
>> prematurely closed when the 'root' incident is resolved but the CA has
>> taken no meaningful steps to bring their PKI back into compliance (yet)
>>
>
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Re: Audit Letter Validation (ALV) on intermediate certs in CCADB

2019-12-19 Thread Wayne Thayer via dev-security-policy
On Tue, Nov 26, 2019 at 6:10 PM Nick Lamb via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On Mon, 25 Nov 2019 14:12:46 -0800
> Kathleen Wilson via dev-security-policy
>  wrote:
>
> > CAs should have been keeping track of and resolving their own known
> > problems in regards to not fully following the BRs and Mozilla
> > policy. For example, I expect that a situation in which I responded
> > with an OK in 2016 would have been corrected in the 3 years since
> > that email was written.
>
> Perhaps to this end it would be useful for Mozilla's periodic survey
> letters to always ask each CA to list any exceptional circumstances they
> believe currently apply to them?
>
>
We've included a question about complying with the intermediate audit
requirements in the January survey, but not a more general question about
exceptions. I feel that an open-ended question such as this will be
confusing for CAs to answer, and moreover I don't want to create the
impression that Mozilla grants exceptions for policy violations because, as
a general rule, we don't.

This would act both as a reminder to Mozilla of any such exceptions
> which they granted but may have assumed meanwhile ceased to be
> relevant, AND to the CA of any such exceptions upon which they find
> themselves still relying.
>
> The publication of CA responses is an opportunity for Mozilla, Peers
> and the wider community to comment on any discrepancy.
>
>
> Nick.
>
>
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DRAFT January 2020 CA Communication

2019-12-19 Thread Wayne Thayer via dev-security-policy
All,

I've drafted a new email and survey that I plan to send to all CAs in the
Mozilla program in early January. it focuses on compliance with the new
(2.7) version of our Root Store Policy. I will appreciate your review and
feedback on the draft:
https://ccadb-public.secure.force.com/mozillacommunications/CACommunicationSurveySample?CACommunicationId=a051J3waNOW

Note that two deadlines have been added to the communication:
* Action 3 specifies that CAs must agree to update their CP/CPS, if needed
to comply, prior to April 1, 2020. This is intended to prevent responses
that we have found unacceptable in the past, e.g. waiting for an annual
audit before updating the CP/CPS.
* Action 5 requires CAs with failed Intermediate ALV results to publish a
plan to correct these problems no later than Feb 15, 2020. Kathleen
announced that we have begun validating audit letters for intermediate
certificates back in October [1], and the requirement for audit statements
to contain the SHA256 fingerprint of each root and intermediate certificate
that was in scope of the audit dates back to 2017. CAs should have already
taken action to resolve these issues, so this deadline is intended to
convey the need for an immediate response.

- Wayne

[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/M7NGwCh14DI/ZPDMRvDzBQAJ
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