On 10/5/2024 6:52 μ.μ., Tim Hollebeek via Servercert-wg wrote:

Whether the comparison should be case sensitive or not is not a question of how “strict” the linter should be, but what the requirements are.  Linters MUST NOT make their own determinations as to what the requirements are, and SHOULD highlight cases like this where ambiguity may be present. For example, it would be sensible to WARN that a value deviates in case from the correct value, and that the requirements are unclear whether that’s allowed (assuming SC-74 had passed in its current form).


I agree with this statement because we are constantly trying to make the requirements very clear that their adherence can actually be coded in linters, even for a text document that is supposed to be read by humans.

However, I would question whether it’s actually even unclear at all. It’s impossible to interpret the highlighted language into a, b, or c, because the language is completely silent on not just capitalization, but the titles themselves.  I interpret the highlighted language as saying you have to include at least every section and subsection, but it doesn’t matter what titles you give those sections or subsections (since there’s no relevant requirements).


Based on the current BRs and EV Guidelines, CP/CPS documents need to be structured in accordance with RFC 3647. That must have meant something for CAs and auditors, so I don't agree that there are no relevant requirements. Some requirements don't need to be fully prescriptive to make sense, and a Qualified Auditor would be in a position to check whether a CP/CPS follows the outline (even with case insensitive or slightly different/clearer wording of the section title), or whether it is structured according to the old EV Guidelines which did not follow the outline at all.

That’s what the highlighted text says, and questions of whether it has to be capitalized the same way miss the fact that it doesn’t even say the same titles need to be used.


Please recall that this came from the MRSP <https://github.com/mozilla/pkipolicy/blob/master/rootstore/policy.md#33-cps-and-cpses> which says "include at least every section and subsection defined in RFC 3647", which is actually a bit worse than what the ballot said, so I think it should also be fixed there :-)

There are also some hilarious errors in 3647 if you look closely.  I think the best path forward would be something along the lines of:

 1. MUST include at least every section and subsection defined in
    Appendix ZZ, and MUST use the section and subsection titles listed
    there
 2. The titles SHOULD be formatted, worded, capitalized and spelled
    the same way, and
 3. Errors in formatting or titling sections of a CPS are not grounds
    for revocation of affected certificates.

And then explicitly list the outline we want in Appendix ZZ.  The outline should be very close to what 3647 says, to avoid unnecessary churn or deviation from IETF standards, but it would give us a chance to fix the obvious errors, and perhaps fix some historical baggage.

The resulting outline could be submitted back to IETF for publication as an update to 3647, which is starting to show its age.


100% onboard with this. It's not a super-urgent matter but I'm confident we'll get the language right and contribute back to IETF.

Dimitris.

-Tim

*From:*Servercert-wg <[email protected]> *On Behalf Of *Roman Fischer via Servercert-wg
*Sent:* Friday, May 10, 2024 4:20 AM
*To:* CA/B Forum Server Certificate WG Public Discussion List <[email protected]> *Subject:* Re: [Servercert-wg] Ballot SC-74 - Clarify CP/CPS structure according to RFC 3647

Hi Wendy,

I would definitely go for c) because the documents are overall not standardized enough to do any kind of automatic parsing where a) or b) would maybe help.

Rgds
Roman

*From:*Servercert-wg <[email protected]> *On Behalf Of *Wendy Brown - QT3LB-C via Servercert-wg
*Sent:* Donnerstag, 9. Mai 2024 16:58
*To:* Aaron Gable <[email protected]>
*Cc:* CA/B Forum Server Certificate WG Public Discussion List <[email protected]> *Subject:* Re: [Servercert-wg] Ballot SC-74 - Clarify CP/CPS structure according to RFC 3647

OK - then I have a question for all those voting on SC74 (as an Associate member rep, I do not have a vote)

How do you interpret the proposed new language:

include at least every section and subsection defined in section 6 of RFC 3647

Does this mean:

a) that the section and subsection headers have to exactly match the text in RFC 3647 including its use of capitalization, or

b) just that the words must be the same or

c) you just have to have the same numbering and the title can be slightly different as long as it covers the intended content?

Sorry to not have asked this during the discussion period, until I saw the output of the linter Aaron prepared, it didn't occur to me that anyone would have interpreted it as the capitalization had to match.

thanks,

Wendy

Wendy Brown

Supporting GSA

FPKIMA Technical Liaison

Protiviti Government Services

703-965-2990 (cell)

On Thu, May 9, 2024 at 10:33 AM Aaron Gable <[email protected]> wrote:

    I think that is a question to be taken up with the authors of
    SC-74, and with the root programs. In the interest of caution, I
    think this linting tool should err on the side of strictness. It
    is open source, however, so you are of course free to modify it
    for your own preferences.

    Aaron

    On Thu, May 9, 2024, 04:57 Wendy Brown - QT3LB-C
    <[email protected]> wrote:

        Aaron -

        Can I suggest that maybe the comparison should be done in a
        case blind fashion?

        For example, requiring the headers for the subsections of 1.3
        to have the second word lower case when it is common practice
        to refer to Certification Authorities as CAs and Registration
        Authorities as RAs, etc. just makes the document inconsistent.
        I understand the goal is to try to make comparisons easier,
        but requiring all Public Trusted CAs have these style
        inconsistencies in their own documentation seems like a step
        too far.

        thanks,

        Wendy

        Wendy Brown

        Supporting GSA

        FPKIMA Technical Liaison

        Protiviti Government Services

        703-965-2990 (cell)

        On Wed, May 8, 2024 at 6:06 PM Aaron Gable via Servercert-wg
        <[email protected]> wrote:

            Of course! Done:
            https://github.com/cabforum/servercert/issues/513
            
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/issues/513___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjhhYzY6ZmJmZTNhY2NmMGM2YmMyZjFhMzhmMjcwY2ExNDFkZTc3NGU5M2NkZDI4MzAyYjQwOWViMzNhMmJmZGRkMzAyMjpoOkY>

            On Wed, May 8, 2024 at 8:37 AM Dimitris Zacharopoulos
            (HARICA) <[email protected]> wrote:

                Thanks Aaron,

                Would it be ok for you to create a GitHub issue
                
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/issues___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmUwNjI6MzFkMjYyMTQ3NzdmNTM5NzExNDRlODRhYmQzZTcyM2RkMWU2MDk2YzExNzY3NDczZjRkM2FiNWYzYWIyZTYxMDpoOkY>
                to identify the specific sections that deviate in
                content? We might tackle that in a cleanup ballot. I
                don't think the capitalization is so much of a concern
                but if others think it is, please speak up :)


                Dimitris.

                On 8/5/2024 1:19 π.μ., Aaron Gable wrote:

                    Two notes on this ballot, findings from our
                    process for handling upcoming requirements:

                    1) Let's Encrypt has created and open-sourced a
                    tool
                    
<https://url.avanan.click/v2/___https:/github.com/letsencrypt/cp-cps/tree/d5b258a/tools/lint___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmNjYjI6MmViY2I4M2Y5MmJlNzU4MWM5YWJhMWRhYjk1YmFiNzc0NTdkOWI1OTA5ZWJiNTkzZGNmMGFjZjk2ZjY3NjhhYTpoOkY>
                    for linting a CPS to confirm compliance with RFC
                    3647 Section 6 and Ballot SC-074. If you maintain
                    your CPS document in markdown, it should be very
                    simple to use or adapt to your particular situation.

                    2) The Baseline Requirements themselves do not
                    quite comply with RFC 3647 Section 6, with several
                    section titles that deviate from that outline in
                    either capitalization or actual content.

                    We hope this information is helpful to others,

                    Aaron

                    On Thu, Apr 25, 2024 at 9:27 AM Dimitris
                    Zacharopoulos (HARICA) via Servercert-wg
                    <[email protected]> wrote:


                          SC-74 - Clarify CP/CPS structure according
                          to RFC 3647


                            Summary

                        The TLS Baseline Requirements require in
                        section 2.2 that:

                        /"The Certificate Policy and/or Certification
                        Practice Statement MUST be structured in
                        accordance with RFC 3647 and MUST include all
                        material required by RFC 3647."/

                        The intent of this language was to ensure that
                        all CAs' CP and/or CPS documents contain a
                        similar structure, making it easier to review
                        and compare against the BRs. However, there
                        was some ambiguity as to the actual structure
                        that CAs should follow. After several
                        discussions in the SCWG Public Mailing List
                        
<https://url.avanan.click/v2/___https:/lists.cabforum.org/pipermail/servercert-wg/2023-November/004070.html___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjJmNjc6ZWM5ZWFhNDJkMmU0MGE0OGYxOWU1OWZkM2NkZmNiMTY3YmFjOWJlZDhiYTZiYzE5ZjBlZWM3MzI5YjYzNTM3NTpoOkY>
                        and F2F meetings, it was agreed that more
                        clarity should be added to the existing
                        requirement, pointing to the outline described
                        in section 6 of RFC 3647.

                        The following motion has been proposed by
                        Dimitris Zacharopoulos (HARICA) and endorsed
                        by Aaron Poulsen (Amazon) and Tim Hollebeek
                        (Digicert).

                        You can view the github pull request
                        representing this ballot here
                        
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/pull/503___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OjNhZmM6MGQ5ZWY1YjVmZDBhMmU2MGRmODhlNjZlZDhlOWEzNzkwOGU2NjA3NTllYzg5MjJlYWViMTJmODQ5NzBiMThkNzpoOkY>.



                            Motion Begins

                        MODIFY the "Baseline Requirements for the
                        Issuance and Management of Publicly-Trusted
                        TLS Server Certificates" based on Version
                        2.0.4 as specified in the following redline:

                          * 
https://github.com/cabforum/servercert/compare/c4a34fe2292022e0a04ba66b5a85df75907ac2a2...f6a90e2a652fbb7a2d62a976b70f4af3adce8dae
                            
<https://url.avanan.click/v2/___https:/github.com/cabforum/servercert/compare/c4a34fe2292022e0a04ba66b5a85df75907ac2a2...f6a90e2a652fbb7a2d62a976b70f4af3adce8dae___.YXAzOmRpZ2ljZXJ0OmE6bzoyZGZmNDkwNjM2NzZkZTVkYTFkY2ZmM2FjZjk2Yzc0Yzo2OmFjNTU6ZGE2MDMwNTE5MDk4OGQyZGQzOTI5ODkxMThhMDNhNzM5NDFhY2ZjYjUwZDE1YWUzNTYzZTE4MjcxZTY4ZDY3ODpoOkY>



                            Motion Ends

                        This ballot proposes a Final Maintenance
                        Guideline. The procedure for approval of this
                        ballot is as follows:


                                Discussion (at least 7 days)

                          * Start time: 2024-04-25 16:30:00 UTC
                          * End time: on or after 2024-05-02 16:30:00 UTC


                                Vote for approval (7 days)

                          * Start time: TBD
                          * End time: TBD

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