I do support this and I have no concerns about implementing this proposal.
However, I'm concerned that we're essentially creating operational best
practices that should already be standard procedure from the RIRs side. The
current model of accepting delegated CA didn't come out of the SIG Policy,
it was an operational decision in order to offer RPKI Services as per
standard, then why a policy required to make any changes in that process?
Today we're addressing non-functional CAs, but tomorrow we'll likely face
different operational issues with CAs not following established operational
norms. This reactive approach isn't sustainable for the long-term health of
the RPKI ecosystem or should be done through policy forums. In APNIC it
takes at least 6-8 months to implement any policy as they can only be
discussed at policy-SIG sessions.

IMO, a significant gap exists in operational standards for delegated
(self-hosted) CAs, with most existing documentation limited to technical
protocol requirements rather than addressing operational best practices,
security standards, or service level expectations. Instead of implementing
piecemeal fixes to individual issues, I recommend developing a best
operating procedures document for Operators of RPKI Services (ORS) that
RIRs can adopt and enforce consistently across their regions.

Regards,

Aftab A. Siddiqui


On Thu, 31 Jul 2025 at 16:22, Bertrand Cherrier via SIG-policy <
[email protected]> wrote:

> Dear SIG members,
>
> A new proposal "prop-166-v001: Revocation of Persistently Non-functional
> RPKI Certification Authorities"
> has been sent to the Policy SIG for review.
>
> It will be presented at the Open Policy Meeting (OPM) at APNIC 60 on
> Thursday, 11 September 2025.
>
>     https://conference.apnic.net/60/program/program/index.html#/day/8/
> <https://conference.apnic.net/59/programme/programme/index.html#/day/8/>
>
> We invite you to review and comment on the proposal on the mailing list
> before the OPM.
>
> The comment period on the mailing list before the OPM is an important part
> of the Policy Development Process (PDP).
> We encourage you to express your views on the proposal:
>
>   - Do you support or oppose this proposal?
>   - Does this proposal solve a problem you are experiencing? If so,
>     tell the community about your situation.
>   - Do you see any disadvantages in this proposal?
>   - Is there anything in the proposal that is not clear?
>   - What changes could be made to this proposal to make it more effective?
>
> Information about this proposal is appended below as well as available at:
>
>     https://www.apnic.net/community/policy/proposals/prop-166/
>
> Regards,
> Bertrand, Shaila, and Ching-Heng
> APNIC Policy SIG Chairs
>
>
>
>
> ---------------------------------------------------------------------------------------
>
> prop-166-v001: Revocation of Persistently Non-functional RPKI
> Certification Authorities
>
>
> ---------------------------------------------------------------------------------------
>
>
> Proposer: Job Snijders ([email protected])
>
>
> 1. Problem statement
> --------------------
>
> APNIC offers users of its RPKI certification service two deployment
> models: "routing management via MyAPNIC" and "Delegated RPKI". In the
> "MyAPNIC"
> setup, APNIC is responsible for timely issuance and publication of new RPKI
> Manifests and CRLs, but in the "Delegated RPKI" setup resource holders
> themselves manage their CA and issuance schedule.
>
> It is technically possible for Delegated RPKI CA infrastructure to be
> offline or otherwise non-functional for extended periods of time, or for
> the
> contents of publication repositories to become stale or otherwise invalid.
>
> A one-time Delegated RPKI CA misconfiguration can result in validators
> collectively attempting hundreds of thousands of synchronization attempts,
> as
> there currently is no 'liveliness' requirement for Delegated RPKI CAs.
>
> This proposal suggests providing a mandate to APNIC to revoke RPKI
> resource certificates associated with longtime non-functional CAs to reduce
> Relying Party workload.
>
> Persistently Non-functional Delegated CAs have subtle adverse effects
> within
> the RPKI ecosystem which may become more pronounced over time.
>
>
> 2. Objective of policy change
> -----------------------------
>
> The objective of this proposal is to reduce futile workloads for RPKI
> Validator instances, given that attempts to fetch & validate data from
> non-functional CAs is a waste of resources.
>
>
> 3. Situation in other regions
> -----------------------------
>
> A similar proposal exists in the RIPE region:
>
> https://www.ripe.net/community/policies/proposals/2025-02/
>
>
> 4. Proposed policy solution
> ---------------------------
>
> If APNIC is unable to discover and validate a Delegated RPKI
> Certification Authority's (CA's) current Manifest and Certification
> Revocation
> List (CRL) for more than two (2) months, that Delegated CA's resource
> certificate should be revoked by APNIC.
>
> APNIC should make reasonable efforts to discover new Manifests, to
> notify the Delegated CA operator if a current Manifest and CRL cannot be
> validated, and to notify the operator if the delegation is revoked.
>
> This policy proposal does NOT target National Internet Registry (NIR)
> RPKI CAs, the proposal only targets pathologically non-functional CAs that
> are
> not NIRs.
>
>
> 5. Advantages / Disadvantages
> -----------------------------
>
> Advantages
>
> - Non-functional CAs offer nothing of value to validators (RPKI Signed
> Payloads
>   are not available without a current and valid Manifest).
>
> - RPKI Cache Validator synchronisation becomes more economic with fewer
>   purposeless publication points to traverse.
>
> - Non-functional CAs besmirch RPKI validator syslog message archives and
> waste
>   CPU cycles and network traffic.
>
> - Revocation is only a minor inconvenience for non-functional CAs (given
> that
>   the configuration already was broken for an extensive period of time),
> but a
>   big deal for any Relying Party (RP) - especially when taking into
> account the
>   many synchronisation attempts made over long periods of time.
>
> - This policy doesn't affect many resource holders; there only is a small
> group
>   of persistently non-functional CAs, some of which have been
> non-functional
>   for more than 2 years already.
>
>
> Disadvantages
>
> - Resource holders might require more than 2 months to complete the
>   initial Delegated CA setup.
>
>   [[[ Counterpoint to the above: initial setup procedures usually only
> takes
>       a few minutes. Resource holders of course are free to simply retry
> the
>       delegated CA setup procedure following revocation. The goal of this
>       policy is NOT to permanently bar resource holders from setting up
>       Delegated CAs, but to curb persistently non-functional delegations.
>       E.g., "please retry Delegated CA enrollment when you are ready". ]]]
>
>
> 6. Impact on APNIC
> ------------------
>
> APNIC will need to set up a process to detect and revoke non-functional
> CAs. Industry standard open-source tooling already is available for this
> task.
>
> 7. References
> -------------
>
> An overview of non-functional RPKI CAs is available here:
> https://console.rpki-client.org/nonfunc.html
>
> The rpki-client software package can detect and report non-functional CAs:
> https://www.rpki-client.org/
> _______________________________________________
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