+1

Il 04/04/2024 04:20, Mohit Kumar via Cscwg-public ha scritto:

Hi Martijn,

Can I confirm that the proposal to protect private keys of Subordinate CAs in an offline state is applicable to only private keys generated for Roots/Subordinate CAs created after the effective date.

Also, per my understanding, the scope of the proposal is limited to only Root/Subordinate CAs issuing Timestamp Certificates for Code Signing (i.e. with the OID 2.23.140.1.4.2). If yes, may be it would be better to clarify the same with the following language update

‘Effective April 15, 2025, a Timestamp Authority MUST protect Private Keys associated with its Root CA certificates and Subordinate CA certificates containing the `id-kp-timeStamping` KeyPurposeId in the `extKeyUsage` extension (per section 7.1.2.2 g) and that issued Timestamp Certificates with the policyidentifier 2.23.140.1.4.2, in a Hardware Crypto Module conforming to the requirements specified in [Section 6.2.7.1](#6271-private-key-storage-for-CA-keys), maintained in a High Security Zone and in an offline state or air-gapped from all other networks.’

Thanks

Mohit

*From:*Cscwg-public <cscwg-public-boun...@cabforum.org> *On Behalf Of *Martijn Katerbarg via Cscwg-public
*Sent:* Tuesday, March 19, 2024 5:04 AM
*To:* cscwg-public@cabforum.org; Dimitris Zacharopoulos (HARICA) <dzach...@harica.gr>
*Subject:* Re: [Cscwg-public] Timestamp Certificate and SubCA updates

The language (https://github.com/cabforum/code-signing/pull/34 ) has been further updated (https://github.com/cabforum/code-signing/pull/34/commits/9288f7ec376b4bbd139dcb596bcb2d1bf9bd7683) based on the below. @Dimitris Zacharopoulos (HARICA) <mailto:dzach...@harica.gr> I replaced “deleted” with “destroyed” in your proposal, as I believe it would fit better in that section.

Are there any further comments? If not I will start the official discussion period in the next few days.

Regards,

Martijn

*From: *Cscwg-public <cscwg-public-boun...@cabforum.org> on behalf of Martijn Katerbarg via Cscwg-public <cscwg-public@cabforum.org>
*Date: *Monday, 11 March 2024 at 09:51
*To: *Dimitris Zacharopoulos (HARICA) <dzach...@harica.gr>, cscwg-public@cabforum.org <cscwg-public@cabforum.org>
*Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates

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Works for me on both fronts. I’ll leave the discussion open for a bit so others can add on.

*From: *Dimitris Zacharopoulos (HARICA) <dzach...@harica.gr>
*Date: *Monday, 11 March 2024 at 09:48
*To: *Martijn Katerbarg <martijn.katerb...@sectigo.com>, cscwg-public@cabforum.org <cscwg-public@cabforum.org>
*Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates

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On 11/3/2024 10:32 π.μ., Martijn Katerbarg wrote:

    Thanks Dimitris, I’ve reviewed and accepted the suggestions.

    > witnessed by members of two different Trusted Roles (not by two Trusted 
Role
    Members, i.e. you can't use two persons of the same Trusted Role).

    TBH, I’m not sure why it couldn’t be two persons of the same
    Trusted Role?


I'm not a native English speaker but I think "Roles" (plural) points to the different types of Roles, while "Trusted Role members" would point to different Members in any Trusted Role. If the intent is to have a 4-eye principle control from any Trusted Role, we can make it clearer by using the "Trusted Role members" phrase.

    > In general, a "key destruction" ceremony includes the deletion of all 
copies
    of the key, including copies that reside in backups. If we require
    a "key destruction" ceremony, the "restore key" case is
    nonsensical. We probably need to work on this some more so that we
    all have the same understanding and expectations.

    > It's ok to keep the keys in backups but if you happen to restore them in 
an
    HSM, you must not use them to sign anything. If a CA/TSA can also
    "destroy" the key, meaning that all copies of that private key can
    be unequivocally/securely deleted (i.e. without a way to recover
    the key), including any instance of the key as part of a backup,
    the better!

    Agreed in general regarding the Key Destruction ceremony. However
    having to also destroy the backup of the key, and do this again
    for any next key every 18 months, can be a lengthy procedure,
    specially if backups are stored securely and offline in different
    places around the world. That’s why for this case we specifically
    call out that backups don’t need to be destroyed.

    But your point on an HSM restoring an entire partition and that
    violating the requirement, is valid.

    For reference, the current proposed language is:

    /The CA MAY maintain existing backup sets containing the Private
    Key corresponding to a Timestamp Certificate. The CA MUST NOT
    restore the Private Key corresponding to a Timestamp Certificate
    contained within the backup if the Timestamp Certificate was
    issued more than 15 months prior to restoration of the backup./

    //

    What about we once more use the NSR language and state:

    /The CA MAY maintain existing backup sets containing the Private
    Key corresponding to a Timestamp Certificate. The CA SHOULD NOT
    restore the Private Key corresponding to a Timestamp Certificate
    contained within the backup if the Timestamp Certificate was
    issued more than 15 months prior to restoration of the backup. If
    the CA does restore such a Private Key, the CA SHALL only restore
    the Private Key in a suitable HSM while it’s maintained in a High
    Security Zone and in an offline state or air-gapped from all other
    networks and perform a new key destruction ceremony prior to the
    HSM being brought to an online state./

    //

    Thoughts?


If we want to allow the existence of a key in a backup, IMHO we should avoid using the "key destruction" language. How about the following:

Modify

    /For Timestamp Certificates issued on or after June 1, 2024, the
    CA SHALL log the removal of the Private Key from the Hardware
    Crypto Module through means of a key destruction ceremony
    performed by the CA and witnessed and signed-off by at least two
    Trusted Roles./


to

    /For Timestamp Certificates issued on or after June 1, 2024, the
    CA SHALL log the removal of the Private Key from the Hardware
    Crypto Module through means of a key deletion ceremony performed
    by the CA and witnessed and signed-off by at least two Trusted
    Role members. The CA MAY also perform a key destruction ceremony,
    /meaning that all copies of that private key are
    unequivocally/securely deleted (i.e. without a way to recover the
    key), including any instance of the key as part of a backup, to
    satisfy this requirement.


Thanks,
Dimitris.

    //

    As a side-note, I wonder if there’s a task for the NSWG (or
    Definitions WG once it’s setup) to define terms for online and
    offline HSMs

    *From: *Cscwg-public <cscwg-public-boun...@cabforum.org>
    <mailto:cscwg-public-boun...@cabforum.org> on behalf of Dimitris
    Zacharopoulos (HARICA) via Cscwg-public
    <cscwg-public@cabforum.org> <mailto:cscwg-public@cabforum.org>
    *Date: *Sunday, 10 March 2024 at 10:30
    *To: *cscwg-public@cabforum.org <cscwg-public@cabforum.org>
    <mailto:cscwg-public@cabforum.org>
    *Subject: *Re: [Cscwg-public] Timestamp Certificate and SubCA updates

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    Hi Martijn,

    Two suggestions submitted on GitHub.

    Regarding the prohibition of restoring a private key of a
    Timestamp Certificate, I'm not sure how universal this can be
    because some HSMs restore an entire slot/partition, which might
    contain Private Keys associated with obsolete Timestamp
    Certificates. As the ballot is written, such an action would be a
    violation.

    In general, a "key destruction" ceremony includes the deletion of
    all copies of the key, including copies that reside in backups. If
    we require a "key destruction" ceremony, the "restore key" case is
    nonsensical. We probably need to work on this some more so that we
    all have the same understanding and expectations.

    Let me restate the intent of this requirement as discussed all
    this time, and please correct me if I'm wrong.

    IMO, the goal is to put the keys associated with Timestamp
    Certificates out of use, 15 months after the /notBefore /of the
    Timestamp Certificate.

    In order to achieve some level of assurance for this action, the
    proposal is to delete the keys from the HSM 18 months after the
    /notBefore /of the Timestamp Certificate, in an audited way,
    witnessed by members of two different Trusted Roles (not by two
    Trusted Role Members, i.e. you can't use two persons of the same
    Trusted Role).

    It's ok to keep the keys in backups but if you happen to restore
    them in an HSM, you must not use them to sign anything. If a
    CA/TSA can also "destroy" the key, meaning that all copies of that
    private key can be unequivocally/securely deleted (i.e. without a
    way to recover the key), including any instance of the key as part
    of a backup, the better!

    Thoughts?

    Dimitris.

    On 6/3/2024 2:07 μ.μ., Martijn Katerbarg via Cscwg-public wrote:

        All,

        As discussed last week, I’d send out the draft language for
        this ballot once more before starting the discussion period. 
        The latest version can be found in
        https://github.com/cabforum/code-signing/pull/34

        I’ve made changes this morning to add 3 effective dates, these
        are:

          * For the removal of private keys associated with timestamp
            certificates, effective June 1^st , 2024, CAs will need to
            properly log the removal of said key.

              o While I expect CAs to already properly log this for
                audit purposes even now, there may be exceptions for
                when this has not been done,  for example a private
                key or timestamp certificate that was signed maybe 20
                years ago. This language is added to avoid any
                confusion on from what point there needs to be an
                audit trail

          * Effective April 15, 2025, private keys associated with
            SubCAs containing the “Time Stamping” EKU will need to be
            placed in offline HSMs.

              o I believe a roughly one year effective date is
                appropriate here, since CAs may need to move keys from
                one HSM to another.

          * For private keys associated with timestamp certificates
            that were issued for greater than 15 months, CAs will need
            to remove the private keys 18 months after certificate
            issuance, starting April 15, 2025.

              o Likewise, I feel like anything involving HSM process
                changes, should have a longer effective date, and it
                makes sense to align this with the effective date above.

        I’ll start a ballot on this early next week, unless there is
        concern with the above.

        Regards,

        Martijn

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