Well, yes, um, that was me 😊

 

There wasn’t an obvious place for contact information for CAs to fit, so I 
suggested section 1.5 when it was discussed on MDSP.  That suggestion migrated 
into the BRs as part of the root program requirement consolidation effort.  
You’re right that it’s outside of the “suggestions” for the official content of 
that section.

 

A similar example is section 1.2, which says:

 

“This subcomponent provides any applicable names or other identifiers,

   including ASN.1 object identifiers, *for the document*.  An example of

   such a document name would be the US Federal Government Policy for

   Secure E-mail.”

 

BR Section 1.2 does not contain the name of the document (“Baseline 
Requirements for the Issuance and Management of Publicly‐Trusted Certificates”) 
and it does not contain any other OIDs or identifiers *for the document*.  The 
expected content would have been something like:

 

----

This document is the CA/Browser Forum TLS requirements, known as “Baseline 
Requirements for the Issuance and Management of Publicly‐Trusted Certificates”, 
version blah.blah.  This version of the document can be referenced by name and 
version, by the URI x://y.z.z/y, or by the OID 
cabf.requirements.baseline.tls.blah.bah.

----

 

That sort of title and version information is what was intended for that 
section.

 

We, instead, have a bunch of OIDs that are intended for indicating compliance 
with the document (which is related, but not the same thing as OIDs identifying 
the document itself).  And then we have the version history and relevant dates 
in that section, which again, is fine, because we’re following an outline, and 
not a normative list of requirements about what MAY / MUST / SHALL NOT / ONLY 
IF YOU ASK NICELY / OVER MY DEAD BODY appear in each section.

 

And I’ve even heard of auditors who have insisted that every single OID the CA 
uses in its operations must be documented in section 1.2.  This is a very 
perverse and difficult to understand misreading of the non-normative text that 
appears in the informative RFC 3647, but I’ve heard of auditors threatening 
audit findings over it (¯\_(ツ)_/¯).  There are other, better places for 
documenting OIDs that are used in certificates.  For example, almost anywhere 
in section 7.

 

-Tim

 

From: Aaron Gable <[email protected]> 
Sent: Friday, December 1, 2023 12:28 PM
To: Tim Hollebeek <[email protected]>; CA/B Forum Server Certificate 
WG Public Discussion List <[email protected]>
Cc: Dimitris Zacharopoulos <[email protected]>; Inigo Barreira 
<[email protected]>
Subject: Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format 
pre-ballot

 

It's also worth noting that the Baseline Requirements also diverge from RFC 
3647 in this way: for example, Section 1.5 of RFC 3647 is concerned with the 
contact information of the group administering the CP/CPS, while Section 
1.5(.2) of the BRs is concerned with contact information of the group operating 
the CA. So trying to cleave too closely to the bulleted descriptions inside RFC 
3647 is unhelpful, imo.

 

For whatever it's worth, I think that Section 11 of the current EVGs could be 
renumbered wholesale to become Section 3.2, retaining its subsections as-is, 
with few or no issues.

 

Aaron

 

On Fri, Dec 1, 2023 at 8:51 AM Tim Hollebeek via Servercert-wg 
<[email protected] <mailto:[email protected]> > wrote:

This is unfortunately wrong.  There are lots of misconceptions about RFC 3647 
“compliance”.

 

The first point is that RFC 3647 is an INFORMATIONAL RFC.  You can see this 
right at the top, where it says “Category: Informational”.  This means that it 
contains no requirements and it’s impossible to be out of compliance with it.  
This is why I put quotes around “compliance”. Any requirements around it need 
to come from elsewhere, for example, a root program requirement that requires a 
particular document to be in RFC 3647 format.  But that’s vague and informal, 
because 3647 doesn’t have requirements, it just has an outline and suggested 
contents.  It’s not 100% precise what “MUST be in RFC 3647 format” means, and 
we need to just acknowledge that (specifying it precisely would be a colossal 
waste of time).

 

So what does “RFC 3647 format” mean?  RFC 3647’s outline only covers the first 
two levels.  So “Section 3.2: Initial Identity Validation” is a RFC 3647 
section header, and most reasonable interpretations of “RFC 3647 format” would 
require it to exist with that or a substantially similar name and contents.

 

Section 3.2.1, on the other hand, is not an RFC 3647 section.  It’s common to 
have a third level of headers that mirror the “bullet points” in the suggested 
content for the section, but those are just unordered bullet lists in RFC 3647. 
 Claiming that section 3.2.1 of a document in RFC 3647 must describe private 
key protection goes beyond what RFC 3647 says.  Section 3.2 just “contains the 
following elements”, so private key protection is just one of several topics 
that one might discuss in section 3.2.  It could be section 3.2.1, but it could 
be elsewhere in 3.2, and it’s perfectly fine for 3.2.1 to not exist, have 
different content, etc.

 

Figuring out where section 11.1 goes is not trivial, but at first glance, 
section 3.2 is not an unreasonable choice, and I can understand why Inigo made 
it.  And there isn’t a compliance reason why it can’t be section 3.2.1, if 
that’s what we want.

 

Of course, we could convert the recommended bulleted sections to a numbered 
list of subsections (we often do elsewhere), in which case section 3.2.1 could 
be “Private Key Protection” with contents “No Stipulation”.  If we do that, I 
suggest we follow the rest of the bullets as well.

 

Either way works.

 

-Tim

 

From: Dimitris Zacharopoulos <[email protected] <mailto:[email protected]> > 
Sent: Friday, December 1, 2023 10:48 AM
To: Inigo Barreira <[email protected] 
<mailto:[email protected]> >
Cc: Tim Hollebeek <[email protected] 
<mailto:[email protected]> >; CA/B Forum Server Certificate WG Public 
Discussion List <[email protected] <mailto:[email protected]> 
>
Subject: Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format 
pre-ballot

 

We MUST comply with RFC 3647 which means that we must include sections that are 
listed in the outline of 3647, and if we have nothing to say, we leave it 
empty. We can't "hijack" the numbering just because we have no requirements to 
describe. 

That's my interpretation of the RFC 3647 compliance. Perhaps others can chime 
in and state their opinion. 


Thanks, 

DZ.

Dec 1, 2023 14:50:23 Inigo Barreira <[email protected] 
<mailto:[email protected]> >:

Thanks Dimitris.

I think that strictly speaking, in RFC 3647 this section is the 4.3.2 Initial 
Identity Validation and the first bullet is about proving the possession of the 
private key, but there´s no specific section other than the general approach 
that we´ve implemented.

That said, the current EVG does not include anything about the possession of 
the private key because that´s covered in the TLS BRs so that section does not 
exist in the EVGs and therefore I didn´t know how to avoid/implement it.

I decided to continue with the normal numbering for an easy checking, so all 11 
section is moved into section 3.2 and the rest of the sub-numbers do not change 
(so 11.1 would be 3.2.1, 11.1.1 would be 3.2.1.1, etc.)

I understand your point but I think we can´t create a section 3.2.1 for private 
key possession because there´s no such a text in the EVGs (and don´t think we 
should add anything new, even a NA for that) and don´t know which other 
sections we can create under 3.2 that can break the current equivalence, which 
again was done for an easy comparison. 

So, what would you suggest to “comply” with that? I don´t have a clear idea.

Regards

De: Dimitris Zacharopoulos (HARICA) <[email protected] 
<mailto:[email protected]> > 
Enviado el: jueves, 30 de noviembre de 2023 13:16
Para: Inigo Barreira <[email protected] 
<mailto:[email protected]> >; Tim Hollebeek 
<[email protected] <mailto:[email protected]> >; CA/B Forum 
Server Certificate WG Public Discussion List <[email protected] 
<mailto:[email protected]> >
Asunto: Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

Inigo,

As I am working to migrate the EV Guidelines into the EV Code Signing Baseline 
Requirements I took a look at the mapping you provided for the EV Guidelines 
and noticed that you are proposing migration of EVG section 11.1 into section 
3.2.1. This particular section is labeled "Method to prove possession of 
private key" in RFC 3647 so I don't think it is appropriate. I think it's best 
to create new subsections under 3.2.

Thanks,
Dimitris.

On 8/9/2023 7:54 Îź.Îź., Inigo Barreira wrote:

Hi all, 

 

Attached you´ll find the EVG v1.8.0 with comments in all sections indicating 
where those sections, and the content, have been moved into the new EVG RFC3647 
format. So, with this document, plus the redlined version, I hope you can have 
now a clearer view of the changes done.

Let me know if you need anything else to clarify the new version.

 

Regards

 

De: Inigo Barreira  <mailto:[email protected]> 
<[email protected]> 
Enviado el: martes, 29 de agosto de 2023 17:06
Para: Tim Hollebeek  <mailto:[email protected]> 
<[email protected]>; Dimitris Zacharopoulos (HARICA)  
<mailto:[email protected]> <[email protected]>; CA/B Forum Server Certificate 
WG Public Discussion List  <mailto:[email protected]> 
<[email protected]>
Asunto: RE: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot

 

Thanks Dimitris and Tim.

I did something of that internally but didn´t reflect on the document, so will 
try to reproduce to have it clearer.

 

OTOH, and as indicated in the PR, the whole section 11 has been placed in 
section 3.2 keeping the rest of the numbering. So, for example:

 

EVG                                     EVG3647

11.1                                    3.2.1

11.1.1                                 3.2.1.1

11.1.2                                 3.2.1.2

11.1.3                                 3.2.1.3

11.2                                    3.2.2

11.2.1                                 3.2.2.1

…..                                       ….           

11.13                                  3.2.13

11.14                                  3.2.14

11.14.1                               3.2.14.1

11.14.2                               3.2.14.2

11.14.3                               3.2.14.3

 

Hope this can clarify the main difficult that I found in the document, where to 
place it and how.

 

Regards

 

De: Tim Hollebeek <[email protected] 
<mailto:[email protected]> > 
Enviado el: martes, 29 de agosto de 2023 16:59
Para: Dimitris Zacharopoulos (HARICA) <[email protected] 
<mailto:[email protected]> >; Inigo Barreira <[email protected] 
<mailto:[email protected]> >; CA/B Forum Server Certificate WG Public 
Discussion List <[email protected] <mailto:[email protected]> 
>
Asunto: RE: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

Yes, exactly.  I would like to see a list that shows that EVG-classic section 
1.4 is now in EVG-3647 section 4.1.  Then I can look at where the new text 
landed, see how the conversion was handled, we can all verify that nothing was 
lost or left out, etc.

 

Without that, anyone attempting to review the document is forced to recreate 
the mapping just to figure out where everything went and that nothing was 
missed or put in the wrong place.  Redlines are not sufficient when large 
amounts of text are moving around to different places.

 

I’m saying this because from my spot-checking, the conversion appears to be 
pretty good, and I’d like to be able to do a final verification that it’s 
mostly correct so I can endorse.

 

-Tim

 

From: Dimitris Zacharopoulos (HARICA) < <mailto:[email protected]> 
[email protected]> 
Sent: Tuesday, August 29, 2023 7:58 AM
To: Inigo Barreira < <mailto:[email protected]> 
[email protected]>; CA/B Forum Server Certificate WG Public Discussion 
List < <mailto:[email protected]> [email protected]>; Tim 
Hollebeek < <mailto:[email protected]> [email protected]>
Subject: Re: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format 
pre-ballot

 

Hi Inigo,

You can take some guidance from previous successful efforts to convert existing 
documents into RFC 3647 format. The latest attempt was in the Code Signing BRs 
conversion in May 2022. Check out the mapping document and the comments in the  
<https://lists.cabforum.org/pipermail/cscwg-public/2022-May/000795.html> ballot 
discussion period.

For each existing section/paragraph, it would be nice to have a comment 
describing where that existing language will land in the converted document 
(destination). This will allow all existing text to be accounted for.

During this process, you might encounter duplicate or redundant text which 
needs to be flagged accordingly. You might also get into some uncertainty as to 
which RFC3647 section is a best fit for existing text that might require 
additional discussion. 

I hope this helps.


Dimitris.

On 29/8/2023 12:42 Îź.Îź., Inigo Barreira via Servercert-wg wrote:

Hi Tim,

 

See attached redlined and current versions. I just used what Martijn suggested 
yesterday but let me know if this is what you were looking for.

 

Regards

 

De: Tim Hollebeek  <mailto:[email protected]> 
<[email protected]> 
Enviado el: lunes, 28 de agosto de 2023 19:49
Para: Inigo Barreira  <mailto:[email protected]> 
<[email protected]>; CA/B Forum Server Certificate WG Public 
Discussion List  <mailto:[email protected]> 
<[email protected]>
Asunto: RE: SC-065: Convert EVGs into RFC 3647 format pre-ballot

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

Thanks for doing this Inigo … I know re-organizations like this are a lot of 
work and fall very much in the category of “important but not fun”.  So thanks 
for taking an initial stab at this.

 

Is there a mapping that shows where all the original text ended up?  I think 
that’s going to be essential for people to be able to review this.  I did some 
spot checking, and your conversion looks pretty good, but I wasn’t able to do a 
more detailed review without a mapping.

 

-Tim

 

From: Servercert-wg < <mailto:[email protected]> 
[email protected]> On Behalf Of Inigo Barreira via 
Servercert-wg
Sent: Monday, August 28, 2023 5:20 AM
To: CA/B Forum Server Certificate WG Public Discussion List < 
<mailto:[email protected]> [email protected]>
Subject: [Servercert-wg] SC-065: Convert EVGs into RFC 3647 format pre-ballot

 

Hello,

The current Extended Validation Guidelines (EVGs) are written in a 
non-standardized format. For many years it has been discussed to convert this 
document into the RFC 3647 format and follow the standardized model for this 
type of documents. 

 

Given that this has been known for several years, I have prepared the following 
ballot text, which converts the EVGs into the RFC 3647 format:

 
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/pull/440___.YXAzOmRpZ2ljZXJ0OmE6bzoyOGIxNWVhZGVmZDlkZTM0NjQzZTA3YTlmYTA2MzM5YTo2OmExZWM6NGZmMGEzM2U0ZWZjOTU4MTM1NWRkNjU3ZDE5YjU3Y2YxNzg1NWU0ZTVjYzkzY2NjM2M0MWU5MzEyYzJmZTQ0NzpoOkY>
 EVGs based on RFC3647 by barrini ¡ Pull Request #440 ¡ cabforum/servercert 
(github.com)

 

I am currently seeking two endorsers as well as any feedback on the ballot 
content itself (wording, effective dates, etc.).

 

Thanks,

 

 

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