On 1/12/2023 7:27 μ.μ., Aaron Gable wrote:
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/.

The group /administrering /the CP/CPS can be included in section "1.5.2  Contact person" along with what the BRs need for the group /operating /the CA. One does not prohibit the other.


So trying to cleave too closely to the bulleted descriptions inside RFC 3647 is unhelpful, imo.

I believe CAs are obligated by policy to include all bulleted section of section 6 of RFC 3647 (plus errata <https://www.rfc-editor.org/errata/rfc3647>).


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.

IMO ... as long as it doesn't conflict with sections/subsections of the outline of RFC 3647.

Dimitris.



Aaron

On Fri, Dec 1, 2023 at 8:51 AM Tim Hollebeek via Servercert-wg <[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]>
    *Sent:* Friday, December 1, 2023 10:48 AM
    *To:* Inigo Barreira <[email protected]>
    *Cc:* Tim Hollebeek <[email protected]>; CA/B Forum
    Server Certificate WG Public Discussion List
    <[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]>:

        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]>
        *Enviado el:* jueves, 30 de noviembre de 2023 13:16
        *Para:* Inigo Barreira <[email protected]>; Tim
        Hollebeek <[email protected]>; CA/B Forum Server
        Certificate WG Public Discussion List <[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 μ.μ., 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 <[email protected]>
            <mailto:[email protected]>
            *Enviado el:* martes, 29 de agosto de 2023 17:06
            *Para:* Tim Hollebeek <[email protected]>
            <mailto:[email protected]>; Dimitris
            Zacharopoulos (HARICA) <[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

            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]>
            *Enviado el:* martes, 29 de agosto de 2023 16:59
            *Para:* Dimitris Zacharopoulos (HARICA)
            <[email protected]>; Inigo Barreira
            <[email protected]>; CA/B Forum Server
            Certificate WG Public Discussion List
            <[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) <[email protected]
            <mailto:[email protected]>>
            *Sent:* Tuesday, August 29, 2023 7:58 AM
            *To:* Inigo Barreira <[email protected]
            <mailto:[email protected]>>; CA/B Forum Server
            Certificate WG Public Discussion List
            <[email protected]
            <mailto:[email protected]>>; Tim Hollebeek
            <[email protected]
            <mailto:[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 ballot discussion period
            
<https://lists.cabforum.org/pipermail/cscwg-public/2022-May/000795.html>.

            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 μ.μ., 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 <[email protected]>
                <mailto:[email protected]>
                *Enviado el:* lunes, 28 de agosto de 2023 19:49
                *Para:* Inigo Barreira <[email protected]>
                <mailto:[email protected]>; CA/B Forum Server
                Certificate WG Public Discussion List
                <[email protected]>
                <mailto:[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
                <[email protected]
                <mailto:[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 <[email protected]
                <mailto:[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:

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

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

                Thanks,

                _______________________________________________

                Servercert-wg mailing list

                [email protected]
                <mailto:[email protected]>

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                <https://lists.cabforum.org/mailman/listinfo/servercert-wg>

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