Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
I made a change to the new section 8.1 language intended to include in the scope both the transfer of existing subordinate CA certificates and the signing of new subordinate CA certificates that are controlled by an organization other than the CA: https://github.com/mozilla/pkipolicy/commit/e3da5aa27bfa02c73b3c474a3aa0420623999333 "Obtains control of" is language that we already use in section 8. For now, I'd like to allow organizations that currently control a subordinate CA certificate to be grandfathered in, and the current proposal does that. The proposals to further strengthen these requirements by requiring public discussion for organizations already in control of a subCA are now documented in issue #195 [1]. Regarding the potentially unclear requirement that notifications are made via email to certifica...@mozilla.org, I'm open to trying to clarify this, but we're not ready to move the notifications into CCADB. I've created issue #149 [2] to track that as a future change. - Wayne [1] https://github.com/mozilla/pkipolicy/issues/195 [2] https://github.com/mozilla/pkipolicy/issues/194 On Fri, Oct 4, 2019 at 5:18 PM Jeremy Rowley wrote: > I did flag that part as wearing my personal hat 😊. > > > > The Trust Italia Sub CA is an example of where confusion may arise in the > policy and where the complexity arises in these relationships. This was not > necessarily a “new” CA from what I understood. This is also why I qualified > the shut down in 2020 as the non-browser TLS. We aren’t expanding the sub > CAs beyond what exists while we figure out what to do with existing > infrastructures that are using them. > > > > That said, still wearing a personal hat, I do think the community should > have access to this information and review the entities that transitively > chain up to the Mozilla root program for sMIME or TLS. There should be a > review of all these sub CAs, including the Trust Italia one we replaced. > The only reason I can see grandfathering is if there are too many to review > at one time. Then grandfather the new ones and review before a new CA is > required to issue. That’ll spur CAs to bring the on-prem Sub CAs forward > for review. > > > > The bigger question to me, is how should this review take place? Should > the root CA sponsor the sub CA and talk about the infrastructure and > operations? I think there should be an established process of how this > occurs, and the process is probably slightly different than roots because > of the extra party (root CA) involved. > > > > *From:* Wayne Thayer > *Sent:* Friday, October 4, 2019 12:40 PM > *To:* Jeremy Rowley > *Cc:* mozilla-dev-security-policy < > mozilla-dev-security-pol...@lists.mozilla.org> > *Subject:* Re: Policy 2.7 Proposal:Extend Section 8 to Encompass > Subordinate CAs > > > > Thanks Jeremy. > > > > On Thu, Oct 3, 2019 at 5:06 PM Jeremy Rowley > wrote: > > Hey Wayne, > > I think there might be confusion on how the notification is supposed to > happen. Is notification through CCADB sufficient? We've uploaded all of the > Sub CAs to CCADB including the technically constrained ICAs. Each one that > is hosted/operated by itself is marked that way using the Subordinate CA > Owner field. Section 8 links to emailing certifica...@mozilla.org but > operationally, CCADB has become the default means of providing this notice. > If you're expecting email, that may be worth clarifying in case CAs missed > that an email is required. I know I missed that, and because CCADB is the > common method of notification there is a chance that notice was considered > sent but not in the expected way. > > > > Considering that section 8 links to an email address where it states "MUST > notify > Mozilla ", I'm skeptical that there is > confusion, but I do agree that it makes sense for the notification to be > triggered via an update to CCADB rather than an email. I'll look in to this. > > > > There's also confusion over the "new to Mozilla" language I think. I > interpreted this language as organizations issued cross-signs after the > policy. For example, Siemens operated a Sub CA through Quovadis prior to > policy date so they aren't "new" to the CA space even if they were > re-certified. > > > > That's the correct interpretation, barring any further clarifications... > > > > However, they would be new in the sense you identified - they haven't gone > through an extensive review by the community. If the goal is to ensure the > community review happens for each Sub CA, then requiring all > recertifications to go through an approval process makes sense instead of > making an excepti
RE: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
I did flag that part as wearing my personal hat 😊. The Trust Italia Sub CA is an example of where confusion may arise in the policy and where the complexity arises in these relationships. This was not necessarily a “new” CA from what I understood. This is also why I qualified the shut down in 2020 as the non-browser TLS. We aren’t expanding the sub CAs beyond what exists while we figure out what to do with existing infrastructures that are using them. That said, still wearing a personal hat, I do think the community should have access to this information and review the entities that transitively chain up to the Mozilla root program for sMIME or TLS. There should be a review of all these sub CAs, including the Trust Italia one we replaced. The only reason I can see grandfathering is if there are too many to review at one time. Then grandfather the new ones and review before a new CA is required to issue. That’ll spur CAs to bring the on-prem Sub CAs forward for review. The bigger question to me, is how should this review take place? Should the root CA sponsor the sub CA and talk about the infrastructure and operations? I think there should be an established process of how this occurs, and the process is probably slightly different than roots because of the extra party (root CA) involved. From: Wayne Thayer Sent: Friday, October 4, 2019 12:40 PM To: Jeremy Rowley Cc: mozilla-dev-security-policy Subject: Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs Thanks Jeremy. On Thu, Oct 3, 2019 at 5:06 PM Jeremy Rowley mailto:jeremy.row...@digicert.com>> wrote: Hey Wayne, I think there might be confusion on how the notification is supposed to happen. Is notification through CCADB sufficient? We've uploaded all of the Sub CAs to CCADB including the technically constrained ICAs. Each one that is hosted/operated by itself is marked that way using the Subordinate CA Owner field. Section 8 links to emailing certifica...@mozilla.org<mailto:certifica...@mozilla.org> but operationally, CCADB has become the default means of providing this notice. If you're expecting email, that may be worth clarifying in case CAs missed that an email is required. I know I missed that, and because CCADB is the common method of notification there is a chance that notice was considered sent but not in the expected way. Considering that section 8 links to an email address where it states "MUST notify Mozilla<mailto:certifica...@mozilla.org>", I'm skeptical that there is confusion, but I do agree that it makes sense for the notification to be triggered via an update to CCADB rather than an email. I'll look in to this. There's also confusion over the "new to Mozilla" language I think. I interpreted this language as organizations issued cross-signs after the policy. For example, Siemens operated a Sub CA through Quovadis prior to policy date so they aren't "new" to the CA space even if they were re-certified. That's the correct interpretation, barring any further clarifications... However, they would be new in the sense you identified - they haven't gone through an extensive review by the community. If the goal is to ensure the community review happens for each Sub CA, then requiring all recertifications to go through an approval process makes sense instead of making an exception for new. I'm not sure how many exist currently, but if there are not that many organizations, does a grandfathering clause cause unnecessary complexity? I realize this is not in DigiCert's best interest, but the community may benefit the most by simply requiring a review of all Sub CAs instead of trying to grandfather in existing cross-signs. Do you have an idea on the number that might entail? At worst, we waste a bunch of time discovering that all of these are perfectly operated and that they could have been grandfathered in the first place. At best, we identify some critical issues and resolve them as a community. It appears to be at least 2 dozen organizations, based on the "subordinate CA owner" field in CCADB. I say "at least" because, as Dimitris noted, we're just now identifying intermediates that are incorrectly labeled as falling under the parent certificate's audits. If there are a significant number of unconstrained on-prem CAs, then language that requires a review on re-signing would be helpful. Perhaps say "As of X date, a CA MUST NOT sign a non-technically constrained certificate where cA=True for keys that are hosted external to the CA's infrastructure or that are not operated in accordance with the issuing CA's policies and procedures unless Mozilla has first granted permission for such certificate"? The wording needs work of course, but the idea is that they go through the discussion and Mozilla signs off. A proce
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
ports, with issues ranging from > missed audit dates to incorrect profile information. The long cycle in > getting information, being a middle-man information gathering, and trying > to convey both Mozilla and CAB forum policy makes controlling compliance > very difficult, and a practice I would not recommend to any CA. Once you've > established a relationship as a signer CA (or acquired a relationship), > extraditing yourself is... difficult. The certificates end up embedded on > smart cards, used by government institutions and pinned in weird places. > And the unfortunate part is you don't have the direct relationship with the > end-user to offer counsel against some of the practices. That extra > abstraction layer between the CA and root store program ends up adding a > lot more complexity than you'd initially think. Delegating the CA > responsibility ends up being a bad idea and takes years to fix. DigiCert is > finally down to the final few TLS sub CAs (5) and each are operating in > OCSP signing mode only. They'll all be revoked in 2020. > > Unless I'm missing something, DigiCert is continuing to issue externally operated S/MIME sub CAs, e.g. https://crt.sh/?id=1652799594 Jeremy > > > -Original Message- > From: dev-security-policy > On Behalf Of Wayne Thayer via dev-security-policy > Sent: Thursday, October 3, 2019 2:45 PM > To: mozilla-dev-security-policy < > mozilla-dev-security-pol...@lists.mozilla.org> > Subject: Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate > CAs > > I'd like to revisit this topic because I see it as a significant change > and am surprised that it didn't generate any discussion. > > Taking a step back, a change [1] to notification requirements was made > last year to require CAs that are signing unconstrained subordinate CAs > (including cross-certs) controlled by a different organization to notify > Mozilla. We have received few, if any, notifications of this nature, so I > have to wonder if CAs are adhering to this requirement. > > This requirement applies as follows: > > an organization other than the CA obtains control of an unconstrained > > intermediate certificate (as defined in section 5.3.2 of this policy) > > that directly or transitively chains to the CA's included > > certificate(s); > > > > Is the "obtains control" language being interpreted to mean that this only > applies when control of the private keys change, and not when a CA signs a > key controlled by a different organization? I believe the intent is for > this to apply in both situations - otherwise it is trivial to bypass. > > The new change [2] proposed for version 2.7 of our policy goes one step > further and places transfers and signings of unconstrained subordinate CAs > clearly in the scope of section 8.1, including the following language: > > If the receiving or acquiring company is new to the Mozilla root program, > > it must demonstrate compliance with the entirety of this policy and > > there MUST be a public discussion regarding their admittance to the > > root program, which Mozilla must resolve with a positive conclusion in > > order for the affected certificate(s) to remain in the root program. > > If the entire CA operation is not included in the scope of the > > transaction, issuance is not permitted until the discussion has been > resolved with a positive conclusion. > > > That means any organization "new to the Mozilla root program" for which a > CA signs an unconstrained subordinate CA or cross-cert must go through an > approval process including a public discussion before issuing certificates > in order to comply with this policy. > > It also means that we need to decide what "new to the Mozilla root program" > means. Organizations that control unconstrained subordinate CAs have not > been considered members of the program in the past, so it's easy to argue > that every such organization will be "new to the Mozilla root program" > if/when this policy goes into effect. However, it may be more practical to > "grandfather in" organizations that are currently in control of > unconstrained subordinate CAs. > > This also raises the question of what it means to "demonstrate compliance > with the entirety of this policy". Section 8.1 has historically applied to > companies acquiring root CAs and we have not required them to go through > the entire inclusion process - only a public discussion. Should that same > interpretation apply to unconstrained subordinate CA? > > Before proposing any changes, I'd like to ask for everyone's input on > these and any other concerns
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
On 2019-10-04 12:56 μ.μ., Rob Stradling wrote: Dimitris, Since CAs should already be disclosing that an intermediate certificate is "externally-operated" by populating the "Subordinate CA Owner" field in the CCADB record, what's the benefit of duplicating this information in the intermediate certificate itself? What happens if an intermediate certificate starts life as "externally-operated" but later becomes "internally-operated", or vice-versa? (e.g., the root CA company acquires the intermediate CA company). It's possible to update a CCADB record. It's not possible to update a certificate. That makes sense. This means that Mozilla has a way to know exactly how many externally-operated CAs are in the Root program, provided all CAs updated this "Subordinate CA Owner" field correctly, meaning that the "Subordinate CA Owner" operates/manages the CA keys. Dimitris. *From:* dev-security-policy on behalf of Dimitris Zacharopoulos via dev-security-policy *Sent:* 04 October 2019 05:43 *To:* mozilla-dev-security-policy *Subject:* Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs Adding to Jeremy's post, I believe we need to also define a normative requirement to mark an unconstrained Intermediate CA Certificate not operated by the entity that controls the Root Key. Section 7.1.6.3 of the Baseline Requirements requires an explicit policy identifier for these subCAs. The anyPolicy identifier is not permitted. So, I assume that all Intermediate CA Certificates that include the anyPolicy identifier should be operated by the Issuing CA (or an Affiliate). Unfortunately -in one sense-, the BRs allow more specific policy identifiers even for Intermediate CA Certificates that ARE operated by the Issuing CA, so it is hard to differentiate which subCA is "Internal" or "External". I believe this is serious enough to consider the possibility of requiring a specific policy identifier (assigned by the CABF) to be included in externally-operated subCA Certificates, in addition to any other policy identifiers that the Issuing CA has chosen for that CA Certificate. Of course, other solutions might be available. Mozilla is also going over a close investigation of unconstrained subCAs that are missing audits and possibly included in oneCRL. I don't believe these subCAs should be grandfathered in. However, others that have supplied audit reports, following Mozilla Policies and indicating compliance with the BRs, should be grandfathered. Dimitris. On 2019-10-04 3:06 π.μ., Jeremy Rowley via dev-security-policy wrote: > Hey Wayne, > > I think there might be confusion on how the notification is supposed to happen. Is notification through CCADB sufficient? We've uploaded all of the Sub CAs to CCADB including the technically constrained ICAs. Each one that is hosted/operated by itself is marked that way using the Subordinate CA Owner field. Section 8 links to emailing certifica...@mozilla.org but operationally, CCADB has become the default means of providing this notice. If you're expecting email, that may be worth clarifying in case CAs missed that an email is required. I know I missed that, and because CCADB is the common method of notification there is a chance that notice was considered sent but not in the expected way. > > There's also confusion over the "new to Mozilla" language I think. I interpreted this language as organizations issued cross-signs after the policy. For example, Siemens operated a Sub CA through Quovadis prior to policy date so they aren't "new" to the CA space even if they were re-certified. However, they would be new in the sense you identified - they haven't gone through an extensive review by the community. If the goal is to ensure the community review happens for each Sub CA, then requiring all recertifications to go through an approval process makes sense instead of making an exception for new. I'm not sure how many exist currently, but if there are not that many organizations, does a grandfathering clause cause unnecessary complexity? I realize this is not in DigiCert's best interest, but the community may benefit the most by simply requiring a review of all Sub CAs instead of trying to grandfather in existing cross-signs. Do you have an idea on the number that might entail > ? At worst, we waste a bunch of time discovering that all of these are perfectly operated and that they could have been grandfathered in the first place. At best, we identify some critical issues and resolve them as a community. > > If there are a significant number of unconstrained on-prem CAs, then language that requires a review on re-signing would be helpful. Perhaps
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
Dimitris, Since CAs should already be disclosing that an intermediate certificate is "externally-operated" by populating the "Subordinate CA Owner" field in the CCADB record, what's the benefit of duplicating this information in the intermediate certificate itself? What happens if an intermediate certificate starts life as "externally-operated" but later becomes "internally-operated", or vice-versa? (e.g., the root CA company acquires the intermediate CA company). It's possible to update a CCADB record. It's not possible to update a certificate. From: dev-security-policy on behalf of Dimitris Zacharopoulos via dev-security-policy Sent: 04 October 2019 05:43 To: mozilla-dev-security-policy Subject: Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs Adding to Jeremy's post, I believe we need to also define a normative requirement to mark an unconstrained Intermediate CA Certificate not operated by the entity that controls the Root Key. Section 7.1.6.3 of the Baseline Requirements requires an explicit policy identifier for these subCAs. The anyPolicy identifier is not permitted. So, I assume that all Intermediate CA Certificates that include the anyPolicy identifier should be operated by the Issuing CA (or an Affiliate). Unfortunately -in one sense-, the BRs allow more specific policy identifiers even for Intermediate CA Certificates that ARE operated by the Issuing CA, so it is hard to differentiate which subCA is "Internal" or "External". I believe this is serious enough to consider the possibility of requiring a specific policy identifier (assigned by the CABF) to be included in externally-operated subCA Certificates, in addition to any other policy identifiers that the Issuing CA has chosen for that CA Certificate. Of course, other solutions might be available. Mozilla is also going over a close investigation of unconstrained subCAs that are missing audits and possibly included in oneCRL. I don't believe these subCAs should be grandfathered in. However, others that have supplied audit reports, following Mozilla Policies and indicating compliance with the BRs, should be grandfathered. Dimitris. On 2019-10-04 3:06 π.μ., Jeremy Rowley via dev-security-policy wrote: > Hey Wayne, > > I think there might be confusion on how the notification is supposed to > happen. Is notification through CCADB sufficient? We've uploaded all of the > Sub CAs to CCADB including the technically constrained ICAs. Each one that is > hosted/operated by itself is marked that way using the Subordinate CA Owner > field. Section 8 links to emailing certifica...@mozilla.org but > operationally, CCADB has become the default means of providing this notice. > If you're expecting email, that may be worth clarifying in case CAs missed > that an email is required. I know I missed that, and because CCADB is the > common method of notification there is a chance that notice was considered > sent but not in the expected way. > > There's also confusion over the "new to Mozilla" language I think. I > interpreted this language as organizations issued cross-signs after the > policy. For example, Siemens operated a Sub CA through Quovadis prior to > policy date so they aren't "new" to the CA space even if they were > re-certified. However, they would be new in the sense you identified - they > haven't gone through an extensive review by the community. If the goal is to > ensure the community review happens for each Sub CA, then requiring all > recertifications to go through an approval process makes sense instead of > making an exception for new. I'm not sure how many exist currently, but if > there are not that many organizations, does a grandfathering clause cause > unnecessary complexity? I realize this is not in DigiCert's best interest, > but the community may benefit the most by simply requiring a review of all > Sub CAs instead of trying to grandfather in existing cross-signs. Do you > have an idea on the number that might entail > ? At worst, we waste a bunch of time discovering that all of these are > perfectly operated and that they could have been grandfathered in the first > place. At best, we identify some critical issues and resolve them as a > community. > > If there are a significant number of unconstrained on-prem CAs, then language > that requires a review on re-signing would be helpful. Perhaps say "As of X > date, a CA MUST NOT sign a non-technically constrained certificate where > cA=True for keys that are hosted external to the CA's infrastructure or that > are not operated in accordance with the issuing CA's policies and procedures > unless Mozilla has f
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
AB forum policy makes controlling compliance very difficult, and a practice I would not recommend to any CA. Once you've established a relationship as a signer CA (or acquired a relationship), extraditing yourself is... difficult. The certificates end up embedded on smart cards, used by government institutions and pinned in weird places. And the unfortunate part is you don't have the direct relationship with the end-user to offer counsel against some of the practices. That extra abstraction layer between the CA and root store program ends up adding a lot more complexity than you'd initially think. Delegating the CA responsibility ends up being a bad idea and takes years to fix. DigiCert is finally down to the final few TLS sub CAs (5) and each are operating in OCSP signing mode only. They'll all be revoked in 2020. Jeremy -Original Message- From: dev-security-policy On Behalf Of Wayne Thayer via dev-security-policy Sent: Thursday, October 3, 2019 2:45 PM To: mozilla-dev-security-policy Subject: Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs I'd like to revisit this topic because I see it as a significant change and am surprised that it didn't generate any discussion. Taking a step back, a change [1] to notification requirements was made last year to require CAs that are signing unconstrained subordinate CAs (including cross-certs) controlled by a different organization to notify Mozilla. We have received few, if any, notifications of this nature, so I have to wonder if CAs are adhering to this requirement. This requirement applies as follows: an organization other than the CA obtains control of an unconstrained intermediate certificate (as defined in section 5.3.2 of this policy) that directly or transitively chains to the CA's included certificate(s); Is the "obtains control" language being interpreted to mean that this only applies when control of the private keys change, and not when a CA signs a key controlled by a different organization? I believe the intent is for this to apply in both situations - otherwise it is trivial to bypass. The new change [2] proposed for version 2.7 of our policy goes one step further and places transfers and signings of unconstrained subordinate CAs clearly in the scope of section 8.1, including the following language: If the receiving or acquiring company is new to the Mozilla root program, it must demonstrate compliance with the entirety of this policy and there MUST be a public discussion regarding their admittance to the root program, which Mozilla must resolve with a positive conclusion in order for the affected certificate(s) to remain in the root program. If the entire CA operation is not included in the scope of the transaction, issuance is not permitted until the discussion has been resolved with a positive conclusion. That means any organization "new to the Mozilla root program" for which a CA signs an unconstrained subordinate CA or cross-cert must go through an approval process including a public discussion before issuing certificates in order to comply with this policy. It also means that we need to decide what "new to the Mozilla root program" means. Organizations that control unconstrained subordinate CAs have not been considered members of the program in the past, so it's easy to argue that every such organization will be "new to the Mozilla root program" if/when this policy goes into effect. However, it may be more practical to "grandfather in" organizations that are currently in control of unconstrained subordinate CAs. This also raises the question of what it means to "demonstrate compliance with the entirety of this policy". Section 8.1 has historically applied to companies acquiring root CAs and we have not required them to go through the entire inclusion process - only a public discussion. Should that same interpretation apply to unconstrained subordinate CA? Before proposing any changes, I'd like to ask for everyone's input on these and any other concerns stemming from this policy proposal. - Wayne [1] https://github.com/mozilla/pkipolicy/commit/7a33f1d065733c19b6030261c1a11f860c30dc10 [2] https://github.com/mozilla/pkipolicy/commit/175aed5f145ae0f29735a13801a5639e70f1f0a8 On Fri, May 10, 2019 at 1:58 PM Wayne Thayer wrote: Having received no comments on these proposed changes, I plan to include them in version 2.7 of our policy. - Wayne On Fri, Apr 19, 2019 at 11:55 AM Wayne Thayer wrote: Ryan Sleevi made the following proposal: Issue #122 [1] previously discussed Section 8 in the context of subordinate CAs, with a change [2] being made to include subordinate CAs (in the context of Section 5.3.2) within scope of notification requirements. However, as presently worded, it's ambiguous as to whether or not Sections 8.1 through 8.3 also ap
RE: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
Hey Wayne, I think there might be confusion on how the notification is supposed to happen. Is notification through CCADB sufficient? We've uploaded all of the Sub CAs to CCADB including the technically constrained ICAs. Each one that is hosted/operated by itself is marked that way using the Subordinate CA Owner field. Section 8 links to emailing certifica...@mozilla.org but operationally, CCADB has become the default means of providing this notice. If you're expecting email, that may be worth clarifying in case CAs missed that an email is required. I know I missed that, and because CCADB is the common method of notification there is a chance that notice was considered sent but not in the expected way. There's also confusion over the "new to Mozilla" language I think. I interpreted this language as organizations issued cross-signs after the policy. For example, Siemens operated a Sub CA through Quovadis prior to policy date so they aren't "new" to the CA space even if they were re-certified. However, they would be new in the sense you identified - they haven't gone through an extensive review by the community. If the goal is to ensure the community review happens for each Sub CA, then requiring all recertifications to go through an approval process makes sense instead of making an exception for new. I'm not sure how many exist currently, but if there are not that many organizations, does a grandfathering clause cause unnecessary complexity? I realize this is not in DigiCert's best interest, but the community may benefit the most by simply requiring a review of all Sub CAs instead of trying to grandfather in existing cross-signs. Do you have an idea on the number that might entail ? At worst, we waste a bunch of time discovering that all of these are perfectly operated and that they could have been grandfathered in the first place. At best, we identify some critical issues and resolve them as a community. If there are a significant number of unconstrained on-prem CAs, then language that requires a review on re-signing would be helpful. Perhaps say "As of X date, a CA MUST NOT sign a non-technically constrained certificate where cA=True for keys that are hosted external to the CA's infrastructure or that are not operated in accordance with the issuing CA's policies and procedures unless Mozilla has first granted permission for such certificate"? The wording needs work of course, but the idea is that they go through the discussion and Mozilla signs off. A process for unconstrained Sub CAs that is substantially similar to the root inclusion makes sense, but there is documentation on CCADB for the existing ones. Still, this documentation should probably made available, along with the previous incident reports, to the community for review and discussion. Afterall, anything not fully constrained is essentially operating the same as a fully embedded root. Speaking on a personal, non-DigiCert note, I think on-prem sub CAs are a bad idea, and I fully support more careful scrutiny on which entities are controlling keys. Looking at the DigiCert metrics, the on-prem Sub CAs are responsible for over half of the incident reports, with issues ranging from missed audit dates to incorrect profile information. The long cycle in getting information, being a middle-man information gathering, and trying to convey both Mozilla and CAB forum policy makes controlling compliance very difficult, and a practice I would not recommend to any CA. Once you've established a relationship as a signer CA (or acquired a relationship), extraditing yourself is... difficult. The certificates end up embedded on smart cards, used by government institutions and pinned in weird places. And the unfortunate part is you don't have the direct relationship with the end-user to offer counsel against some of the practices. That extra abstraction layer between the CA and root store program ends up adding a lot more complexity than you'd initially think. Delegating the CA responsibility ends up being a bad idea and takes years to fix. DigiCert is finally down to the final few TLS sub CAs (5) and each are operating in OCSP signing mode only. They'll all be revoked in 2020. Jeremy -Original Message- From: dev-security-policy On Behalf Of Wayne Thayer via dev-security-policy Sent: Thursday, October 3, 2019 2:45 PM To: mozilla-dev-security-policy Subject: Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs I'd like to revisit this topic because I see it as a significant change and am surprised that it didn't generate any discussion. Taking a step back, a change [1] to notification requirements was made last year to require CAs that are signing unconstrained subordinate CAs (including cross-certs) controlled by a different organization to notify Mozilla.
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
I'd like to revisit this topic because I see it as a significant change and am surprised that it didn't generate any discussion. Taking a step back, a change [1] to notification requirements was made last year to require CAs that are signing unconstrained subordinate CAs (including cross-certs) controlled by a different organization to notify Mozilla. We have received few, if any, notifications of this nature, so I have to wonder if CAs are adhering to this requirement. This requirement applies as follows: an organization other than the CA obtains control of an unconstrained > intermediate certificate (as defined in section 5.3.2 of this policy) that > directly or transitively chains to the CA's included certificate(s); > Is the "obtains control" language being interpreted to mean that this only applies when control of the private keys change, and not when a CA signs a key controlled by a different organization? I believe the intent is for this to apply in both situations - otherwise it is trivial to bypass. The new change [2] proposed for version 2.7 of our policy goes one step further and places transfers and signings of unconstrained subordinate CAs clearly in the scope of section 8.1, including the following language: If the receiving or acquiring company is new to the Mozilla root program, > it must demonstrate compliance with the entirety of this policy and there > MUST be a public discussion regarding their admittance to the root program, > which Mozilla must resolve with a positive conclusion in order for the > affected certificate(s) to remain in the root program. If the entire CA > operation is not included in the scope of the transaction, issuance is not > permitted until the discussion has been resolved with a positive conclusion. That means any organization "new to the Mozilla root program" for which a CA signs an unconstrained subordinate CA or cross-cert must go through an approval process including a public discussion before issuing certificates in order to comply with this policy. It also means that we need to decide what "new to the Mozilla root program" means. Organizations that control unconstrained subordinate CAs have not been considered members of the program in the past, so it's easy to argue that every such organization will be "new to the Mozilla root program" if/when this policy goes into effect. However, it may be more practical to "grandfather in" organizations that are currently in control of unconstrained subordinate CAs. This also raises the question of what it means to "demonstrate compliance with the entirety of this policy". Section 8.1 has historically applied to companies acquiring root CAs and we have not required them to go through the entire inclusion process - only a public discussion. Should that same interpretation apply to unconstrained subordinate CA? Before proposing any changes, I'd like to ask for everyone's input on these and any other concerns stemming from this policy proposal. - Wayne [1] https://github.com/mozilla/pkipolicy/commit/7a33f1d065733c19b6030261c1a11f860c30dc10 [2] https://github.com/mozilla/pkipolicy/commit/175aed5f145ae0f29735a13801a5639e70f1f0a8 On Fri, May 10, 2019 at 1:58 PM Wayne Thayer wrote: > Having received no comments on these proposed changes, I plan to include > them in version 2.7 of our policy. > > - Wayne > > On Fri, Apr 19, 2019 at 11:55 AM Wayne Thayer wrote: > >> Ryan Sleevi made the following proposal: >> >> Issue #122 [1] previously discussed Section 8 in the context of >>> subordinate CAs, with a change [2] being made to include subordinate CAs >>> (in the context of Section 5.3.2) within scope of notification requirements. >>> >>> However, as presently worded, it's ambiguous as to whether or not >>> Sections 8.1 through 8.3 also apply to subordinate CAs, or whether the only >>> disclosure required is upon the initial introduction of the subordinate. >>> This confusion results from language such as in Section 8.1, "or when an >>> organization buys the private key of a certificate in Mozilla's root >>> program", implying that private keys which transitively chain to a root >>> certificate within Mozilla's program are exempt from such requirements. >>> >>> This ambiguity creates incentives for situations such as cross-signing >>> CAs that might otherwise or have been otherwise rejected from direct >>> inclusion within the Mozilla program. It further creates issues with >>> respect to the supervision of audits and auditors. >>> >>> While it is true that the signing CA accepts the risk that an >>> unfavorable verdict on the subordinate may impact the root, the cost of >>> such a decision is primarily borne by Mozilla and the broader community, in >>> that they are responsible for the collateral ecosystem challenges and >>> devising appropriate solutions. This has been demonstrated, for example, >>> through the discussion of Symantec issues [3]. >>> >>> Because Mozilla and the community bear significant cost,
Re: Policy 2.7 Proposal:Extend Section 8 to Encompass Subordinate CAs
Having received no comments on these proposed changes, I plan to include them in version 2.7 of our policy. - Wayne On Fri, Apr 19, 2019 at 11:55 AM Wayne Thayer wrote: > Ryan Sleevi made the following proposal: > > Issue #122 [1] previously discussed Section 8 in the context of >> subordinate CAs, with a change [2] being made to include subordinate CAs >> (in the context of Section 5.3.2) within scope of notification requirements. >> >> However, as presently worded, it's ambiguous as to whether or not >> Sections 8.1 through 8.3 also apply to subordinate CAs, or whether the only >> disclosure required is upon the initial introduction of the subordinate. >> This confusion results from language such as in Section 8.1, "or when an >> organization buys the private key of a certificate in Mozilla's root >> program", implying that private keys which transitively chain to a root >> certificate within Mozilla's program are exempt from such requirements. >> >> This ambiguity creates incentives for situations such as cross-signing >> CAs that might otherwise or have been otherwise rejected from direct >> inclusion within the Mozilla program. It further creates issues with >> respect to the supervision of audits and auditors. >> >> While it is true that the signing CA accepts the risk that an unfavorable >> verdict on the subordinate may impact the root, the cost of such a decision >> is primarily borne by Mozilla and the broader community, in that they are >> responsible for the collateral ecosystem challenges and devising >> appropriate solutions. This has been demonstrated, for example, through the >> discussion of Symantec issues [3]. >> >> Because Mozilla and the community bear significant cost, especially as >> more time passes and more certificates are issued, the following changes >> are suggested: >> >>1. Align Section 8, and its subsections, with language similar to >>that of Section 3.1.2.1. That is, that the policy is applicable to a CA >> and >>all subordinate CAs technically capable of issuing (server or e-mail) >>certificates >>2. With respect to Section 8.1, extend the requirements of the last >>paragraph to the issuance of subordinate CA certificates. Namely, if the >>private key is in possession of an entity that is new to the Mozilla root >>program, or subject to a CP or CPS that is new to the Mozilla Root >> Program, >>that prior to the issuance of such a certificate, there be a public >>discussion that results in a favorable conclusion. >> >> With the current policy as written, an existing/included root CA that >> plans to exit the CA business might be prohibited (by virtue of Section >> 8.1) from selling the business or (by virtue of Section 8.3) from >> transferring the private key material. However, they are fully permitted to >> cross-certify a new 'root' and then proverbially close up shop - with no >> consideration for if their root gets removed as a consequence. These are >> the same set of concerns that led to the introduction of Section 8, but >> today exist due to the ambiguity with respect to the subsections. >> > > I've proposed a fix for this issue: > https://github.com/mozilla/pkipolicy/commit/175aed5f145ae0f29735a13801a5639e70f1f0a8 > It also attempts to clarify the applicability of section 8.3 as "only" > when section 8.1 and/or section 8.2 also apply. > > This is https://github.com/mozilla/pkipolicy/issues/169 and > https://github.com/mozilla/pkipolicy/issues/140 > > I will greatly appreciate everyone's input on this topic. In particular, I > would like to hear from CAs that would be affected by the requirement for > any new subordinate CAs to go through a public discussion before issuing > certificates, with the outcome being positive or else the subordinate CA > certificate will be added to OneCRL (section 8.1). > > - Wayne > > [1] https://github.com/mozilla/pkipolicy/issues/122 > [2] > https://github.com/mozilla/pkipolicy/commit/7a33f1d065733c19b6030261c1a11f860c30dc10 > [3] https://wiki.mozilla.org/CA:Symantec_Issues > ___ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
