Since there’s no further comments, I will start version 2 of this ballot’s 
discussion period in the next 24 hours based on the feedback received from 
Clint, unless there are further comments. 

From: Servercert-wg <[email protected]> on behalf of Martijn 
Katerbarg via Servercert-wg <[email protected]>
Date: Wednesday, 7 February 2024 at 12:22
To: Ponds-White, Trev <[email protected]>, CA/B Forum Server Certificate WG 
Public Discussion List <[email protected]>, Tim Hollebeek 
<[email protected]>, Christophe Bonjean 
<[email protected]>
Subject: Re: [Servercert-wg] [Discussion Period Begins]: SC-69 Clarify router 
and firewall logging requirements 

CAUTION: This email originated from outside of the organization. Do not click 
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is safe. 


So, to capture some of this. The reason we’ve started address this line itself 
(route and firewall activities) is because it’s been interpreted by some as 
“anything the device does”, such as routing a single package. That’s the main 
item I’m trying to clarify within this ballot. 

Taking another deeper dive in this, Section 5.4.1 starts with “SHALL record 
events related to the security of their Certificate Systems, Certificate 
Management Systems, Root CA Systems, and Delegated Third Party Systems.” – The 
fact that there’s a separate line for router and firewall activities, suggests 
that those may not fall under the definition of Certificate System, Certificate 
Management System or Root CA System. Looking at the definitions, I’d say router 
and firewalls fall under the Certificate Systems definition, since they are 
used in “…providing…validity status…”. 

If we then go back to the “what must a CA log” question, there’s already a line 
showing “Successful and unsuccessful PKI system access attempts;”. Does the 
fact that this say “PKI system”, suddenly remove routers and firewalls from the 
scope of that item? 

Almost similar, though not stating PKI systems, there already is a line for 
Security Profile Changes, which might as well incorporate firewall rule changes 
and configuration changes, and Christopher also pointed our correctly. System 
crashes, hardware failures and other anomalies is already covered. By other 
bullet points as well. 

With that in mind, is there even really any reason at all, for keeping “router 
and firewall activities” in there? 

I’ll answer the question from my point of view: I’d say yes, because it 
clarifies further that routers and firewall are in scope, and here’s what the 
CA needs to log for them. I don’t see a harm of providing that extra clarity in 
the BRs. 

Thoughts? 

From: Servercert-wg <[email protected]> on behalf of 
Ponds-White, Trev via Servercert-wg <[email protected]>
Date: Tuesday, 6 February 2024 at 22:50
To: Tim Hollebeek <[email protected]>, CA/B Forum Server Certificate 
WG Public Discussion List <[email protected]>, Christophe Bonjean 
<[email protected]>
Subject: Re: [Servercert-wg] [Discussion Period Begins]: SC-69 Clarify router 
and firewall logging requirements 

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. 


Do we think that is already sufficiently taken care of by #5 (System crashes, 
hardware failures, and other anomalies;) on the security events list then? Or 
does it need to be specifically repeated for this item? 

From: Tim Hollebeek <[email protected]> 
Sent: Tuesday, February 6, 2024 10:08 AM
To: Ponds-White, Trev <[email protected]>; CA/B Forum Server Certificate WG 
Public Discussion List <[email protected]>; Christophe Bonjean 
<[email protected]>
Subject: RE: [EXTERNAL] [Servercert-wg] [Discussion Period Begins]: SC-69 
Clarify router and firewall logging requirements 



There are a number of attack scenarios that cause network devices to 
crash/restart either as part of the attack, or as a consequence of the fallout 
from an attack. So paying attention to if some of your network hardware and 
software crashes unexpectedly and/or becomes significantly less stable can be a 
useful signal. 

That’s at least the historical reason for including this sort of monitoring, 
I’ll ask Bindi if it still makes sense to be watching for that sort of stuff 
today. 

-Tim 

From: Servercert-wg <[email protected] 
<mailto:[email protected]>> On Behalf Of Ponds-White, Trev via 
Servercert-wg
Sent: Tuesday, February 6, 2024 12:59 PM
To: Christophe Bonjean <[email protected] 
<mailto:[email protected]>>; CA/B Forum Server Certificate WG 
Public Discussion List <[email protected] 
<mailto:[email protected]>>
Subject: Re: [Servercert-wg] [Discussion Period Begins]: SC-69 Clarify router 
and firewall logging requirements 



I had the same thought about firewall rules vs configuration changes being 
duplicative. I also agree about the dubious value of “hardware failures, 
software crashes, and system restarts”. I left it in since it was there but I 
was kind of struggling to figure out the purpose of some of that information. I 
assume its there for the purpose of understanding the impact and duration of an 
unexpected outage of your boundary protections? I don’t think that list really 
gets you that but it might be a piece of the picture for some, but not all, 
environments. 

From: Christophe Bonjean <[email protected] 
<mailto:[email protected]>> 
Sent: Tuesday, February 6, 2024 5:39 AM
To: Ponds-White, Trev <[email protected] <mailto:[email protected]>>; CA/B 
Forum Server Certificate WG Public Discussion List <[email protected] 
<mailto:[email protected]>>
Subject: RE: [EXTERNAL] [Servercert-wg] [Discussion Period Begins]: SC-69 
Clarify router and firewall logging requirements 



I agree with Trev’s perspective. 

A few comments: 

* Firewall rules are a separate item, but aren’t firewall rules covered by 
configuration changes? Should we merge it?
* What’s the purpose of “hardware failures, software crashes, and system 
restarts”? System restarts I could see how it’s relevant for audit logging 
purposes, but not sure what the additional value is of logging hardware 
failures and software crashes.

Christophe 


From: Servercert-wg <[email protected] 
<mailto:[email protected]>> On Behalf Of Ponds-White, Trev via 
Servercert-wg
Sent: Tuesday, February 6, 2024 3:08 AM
To: Martijn Katerbarg <[email protected] 
<mailto:[email protected]>>; CA/B Forum Server Certificate WG 
Public Discussion List <[email protected] 
<mailto:[email protected]>>; Clint Wilson <[email protected] 
<mailto:[email protected]>>
Subject: Re: [Servercert-wg] [Discussion Period Begins]: SC-69 Clarify router 
and firewall logging requirements 



I think “router and firewall activities” are solutions that don’t identify the 
problem we are trying to solve. Ultimately we want to know that the CA systems 
are segregated and protected. In this section we are specifying the required 
logs the CAs should have that allow them to monitor this and investigate if 
issues occur. I think it would be better to change this something like 

“Network boundary controls (firewall, switch, router, gateway, or other network 
control device or system) activities. Relevant activities to log include 
configuration changes, firmware updates, and access control modifications. As 
well as system events and errors, including hardware failures, software 
crashes, and system restarts.” 

This also better aligns with NetSec 1.f “Configure each network boundary 
control (firewall, switch, router, gateway, or other network control device or 
system) with rules that support only the services, protocols, ports, and 
communications that the CA has identified as necessary to its operations;” 



From: Servercert-wg <[email protected] 
<mailto:[email protected]>> On Behalf Of Martijn Katerbarg via 
Servercert-wg
Sent: Monday, February 5, 2024 12:52 PM
To: Clint Wilson <[email protected] <mailto:[email protected]>>; ServerCert CA/BF 
<[email protected] <mailto:[email protected]>>
Subject: RE: [EXTERNAL] [Servercert-wg] [Discussion Period Begins]: SC-69 
Clarify router and firewall logging requirements 



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

Hi Clint,

Thanks for the feedback! 


1. I’m not sure the wording "Router and firewall activities" is considered an 
unspecified term, and leaves the exact definition and scope up to the CA, 
however” is necessary or even really helpful. I think it would be clearer to 
introduce Section 5.4.1.1 with something like “Logging of router and firewall 
activities necessary to meet the requirements of Section 5.4.1, Subsection 3.6 
MUST at a minimum include:”
I’d agree, this makes sense to update. 


* I’m not sold on the “Subsection” part, but I don’t recall if we have good 
semantics established for referencing the numbered paragraphs/sections under a 
Section heading.

This was more a design decision, since Section 5.4.1 is already a lengthy 
section with a lot of information. Personally I feel creating the subsection 
make it easier to follow through. I’m open to changing if more people feel this 
should be addressed. 


1. I think the entire section including and under "Logging of router and 
firewall activities SHOULD NOT include:” should be removed. 
Based on the reasoning provided, I agree that it doesn’t really add anything 
extra to the requirements. 


1. The concluding sentence "CAs are encouraged to recommend additional MUST and 
SHOULD NOT requirements through an email to [email protected] 
<mailto:[email protected]>, for future discussion within the appropriate 
Working Group.” stands out as I think it’s the only such “encouragement” in the 
BRs. I don’t think that makes it bad or that it should be removed, but I’m also 
not sure how valuable it is to the BRs as a policy. I admit that may be because 
I view this encouragement as fundamental to membership and participation in the 
CA/B Forum at all — every member, regardless of type, should feel welcome and 
encouraged to recommend changes to any of the CA/B Forum documents. But we 
don’t say that anywhere, so maybe this is a good start?
I took this approach from the CSWG, which used it during the switch to 
hardware-based keys. I’m not sure it was ever utilized however. 
If there’s strong opinions on removing this, I don’t have a problem with that. 

I’ll leave the comments open for a bit, before I make the above changes, in 
case there is more feedback. 

Regards,

Martijn 

From: Clint Wilson <[email protected] <mailto:[email protected]>>
Date: Saturday, 3 February 2024 at 01:13
To: Martijn Katerbarg <[email protected] 
<mailto:[email protected]>>, ServerCert CA/BF 
<[email protected] <mailto:[email protected]>>
Subject: Re: [Servercert-wg] [Discussion Period Begins]: SC-69 Clarify router 
and firewall logging requirements 

Hi Martijn, 


Thanks for sending this out for discussion. Just a few comments at this point: 




1. I’m not sure the wording "Router and firewall activities" is considered an 
unspecified term, and leaves the exact definition and scope up to the CA, 
however” is necessary or even really helpful. I think it would be clearer to 
introduce Section 5.4.1.1 with something like “Logging of router and firewall 
activities necessary to meet the requirements of Section 5.4.1, Subsection 3.6 
MUST at a minimum include:” 


* I’m not sold on the “Subsection” part, but I don’t recall if we have good 
semantics established for referencing the numbered paragraphs/sections under a 
Section heading.


1. I think the entire section including and under "Logging of router and 
firewall activities SHOULD NOT include:” should be removed. 


* The first item listed seems overly broad (arguably, imo, even covering the 
“inbound and outbound” connections of the second item) and so making it a 
SHOULD NOT seems too strong a recommendation.
* The second item seems counterintuitive and difficult to implement 
correctly+consistently. It could be read as something like “don’t log unless 
you know you’re being exploited”, which doesn’t sound like a recommendation we 
should be making (especially in the context of post-incident data analysis).
* Neither of these recommendations seems necessary to accomplish the goals of 
additional clarity and specificity of what MUST be logged.


1. The concluding sentence "CAs are encouraged to recommend additional MUST and 
SHOULD NOT requirements through an email to [email protected] 
<mailto:[email protected]>, for future discussion within the appropriate 
Working Group.” stands out as I think it’s the only such “encouragement” in the 
BRs. I don’t think that makes it bad or that it should be removed, but I’m also 
not sure how valuable it is to the BRs as a policy. I admit that may be because 
I view this encouragement as fundamental to membership and participation in the 
CA/B Forum at all — every member, regardless of type, should feel welcome and 
encouraged to recommend changes to any of the CA/B Forum documents. But we 
don’t say that anywhere, so maybe this is a good start?


Cheers! 

-Clint 


On Jan 29, 2024, at 10:30 AM, Martijn Katerbarg via Servercert-wg 
<[email protected] <mailto:[email protected]>> wrote: 


Summary: 
This ballot aims to clarify what data needs to be logged as part of the 
"Firewall and router activities" logging requirement in the Baseline 
Requirements. 
This ballot is proposed by Martijn Katerbarg (Sectigo) and endorsed by Daniel 
Jeffery (Fastly) and Ben Wilson (Mozilla). 
--- Motion Begins --- 
This ballot modifies the “Baseline Requirements for the Issuance and Management 
of Publicly-Trusted Certificates" ("Baseline Reuqirements"), based on Version 
2.0.2. 
MODIFY the Baseline Requirements as specified in the following Redline: 
https://github.com/cabforum/servercert/compare/41f01640748fa612386f8b1a3031cd1bff3d4f35...807675c91c8500157b0ffd58ab3a40b0b17075e5
 <Protected by Avanan: 
https://github.com/cabforum/servercert/compare/41f01640748fa612386f8b1a3031cd1bff3d4f35...807675c91c8500157b0ffd58ab3a40b0b17075e5>
 
--- Motion Ends --- 
This ballot proposes a Final Maintenance Guideline. The procedure for approval 
of this ballot is as follows: 
Discussion (at least 7 days)

1. Start time: 2024-01-29 18:30:00 UTC
2. End time: not before 2024-02-05 18:30:00 UTC 
Vote for approval (7 days)

1. Start time: TBD
2. End time: TBD

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