Added " Although not expressed in the bug, it appears that certificate
revocation was delayed as well."

On Fri, May 10, 2024 at 10:54 AM George <geo...@fozzie.dev> wrote:

> Although it was not mentioned in the original bug, it may be worth adding
> that the certificates in bug 1867130
> <https://bugzilla.mozilla.org/show_bug.cgi?id=1867130> were also not
> revoked within 5 days of discovery. Entrust might've based the start of the
> 5 day deadline at the time the "Director of compliance confirmed
> investigation conclusions to support team" at 2023-11-21 15:00 UTC with all
> certificates being revoked by 2023-11-26 14:50 UTC, but I don't think
> that's correct if that was the case.
>
> On Friday, May 10th, 2024 at 5:27 PM, 'Ben Wilson' via
> dev-security-policy@mozilla.org <dev-security-policy@mozilla.org> wrote:
>
> Here are draft summaries of the additional historic incidents. I'll be
> adding these to the Entrust Issues page:
> https://wiki.mozilla.org/CA/Entrust_Issues
>
> *Invalid data in State/Province Field -*
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1658792
>
> It was initially discovered that Entrust had issued 395 OV SSL
> certificates to a large international organization with “NA” for the
> state/province information. Entrust worked on a drop-down list to prevent
> the error. Certificate revocation would not occur within established
> timeframes, so Bug #1658794 for delayed revocation was opened.
>
> *Late Revocation for Invalid State/Province Issue - *
> https://bugzilla.mozilla.org/show_bug.cgi?id=1658794
>
> This is the delayed revocation bug related to Bug #1658792, above. Entrust
> said that when educating large institutions about rapid revocation, factors
> include who owns a certificate, where it is deployed, and the type of
> system or application that requires the certificate. It also said that it
> was advocating automation with such institutions to help speed up
> certificate replacement and to minimize human error.
>
> *EV TLS Certificate incorrect jurisdiction -*
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1802916
>
> Entrust mis-issued 322 EV certificates with the wrong state and locality
> jurisdiction fields due to complex data entry processes. Entrust
> implemented a different automated dropdown system for jurisdiction
> selection. Certificate revocation would not occur within established
> timeframes, so Bug #1804753 for delayed revocation was opened.
>
> *Delayed Revocation for EV TLS Certificate incorrect jurisdiction - *
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753
>
> This is the delayed revocation bug related to Bug #1802916, above. Entrust
> listed 8 Subscribers who were pushing back on immediate certificate
> revocation and the reasons given (e.g. extensions granted due to
> end-of-year freezes). Entrust committed to “continue to develop and extend
> methods for automatic certificate renewal.”
>
> *Jurisdiction Locality Wrong in EV Certificate -*
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1867130
>
> Two EV TLS Certificates were mis-issued due to human error in the
> Jurisdiction Locality field. (The incident revealed 340 additional accounts
> needing similar updates.) Entrust said it would enhance its linting
> processes to include possibly using an external service to validate
> locality data against verified country data.
>
> *SHA-256 hash algorithm used with ECC P-384 key - *
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1648472
>
> A Mozilla policy was adopted to require hashing with SHA-384 for an ECC
> P-384 key. Existing CAs using SHA-256 were not re-configured when Mozilla
> adopted this policy. This incident revealed a serious gap in taking new
> requirements and implementing them. Ryan Sleevi noted that linting was just
> a safety net and not a systemic solution. Entrust was also criticized for
> the lack of detail in its incident report and its decision to not revoke
> the certificates.
>
> Entrust committed to improving its monitoring and implementation of policy
> changes to prevent similar incidents. Ryan set forth a number of proactive
> systemic corrections that Entrust needed to take, rather than taking a
> reactive stance on matters of non-compliance.
>
> Entrust committed to rigorous review of certificate profiles, browser
> policy revisions, and industry developments. As a final comment, Ryan said,
> “My big concern is, going forward, we see incident reports from Entrust
> take a more systemic, holistic response, like Comment #16, to try and cover
> the scenarios, and to provide sufficient detail about the situation and its
> failures to understand how those relate. The goal isn't to make CAs wear
> proverbial sackcloth, it's to try and make sure we're understanding how
> things go wrong, so that we can effectively collaborate on identifying
> solutions to avoid that going forward.”
>
> *Late Revocation due to SHA-256 hash algorithm - *
>
> https://bugzilla.mozilla.org/show_bug.cgi?id=1651481
>
> This bug is related to Bug #1648472. Entrust issued TLS certificates
> using ECC P-384 keys hashed with SHA-256, contrary to Mozilla policy
> requiring SHA-384 for hashing. Entrust’s initial decision was to allow
> certificates to expire naturally without revocation, but this was revised
> with a decision to revoke all affected certificates. Entrust committed to:
> filing incident report within one business day for future incidents, filing
> late revocation incident reports within the required 24 hours or 5 days, as
> applicable, and advising Subscribers about revocation within 24 hours or 5
> days, or provide an explanation if they are unable to meet such timeframes.
> Entrust was told it needed to align its revocation procedures more closely
> with the Baseline Requirements and Mozilla’s policy, especially in
> providing a detailed rationale for any delays in revocation on a
> per-subscriber basis and ensuring timely revocation in line with the
> Baseline Requirements.
>
>
> On Thu, May 9, 2024 at 8:13 PM Watson Ladd <watsonbl...@gmail.com> wrote:
>
>> Could we add a section for geographical incidents? This is slightly
>> outside your time window, but I think reading the series here has some
>> uncanny echos in the ones in your window.
>>
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1658792
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1658794
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1802916
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1804753
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1867130
>>
>> On Tue, May 7, 2024 at 7:59 AM 'Ben Wilson' via
>> dev-security-policy@mozilla.org <dev-security-policy@mozilla.org>
>> wrote:
>> >
>> > Dear Mozilla Community,
>> >
>> > Over the past couple of months, a substantial number of compliance
>> incidents have arisen in relation to Entrust. We have summarized these
>> recent incidents in a dedicated wiki page:
>> https://wiki.mozilla.org/CA/Entrust_Issues. In brief, these incidents
>> arose out of certificate mis-issuance due to a misunderstanding of the EV
>> Guidelines, followed by numerous mistakes in incident handling (including a
>> deliberate decision to continue mis-issuance), which have been compounded
>> by a failure to remediate the issues in a timely fashion in line with
>> well-established norms and root store requirements.
>> >
>> > Our preliminary assessment of these incidents is that while they were
>> relatively minor initially, the poor incident response has substantially
>> aggravated them and the progress towards full remediation remains
>> unacceptably slow. This is particularly disappointing in light of previous
>> incidents in 2020 (#1651481 and #1648472), which arose out of similar
>> misunderstandings of the requirements, similar poor decision-making in the
>> initial response, and lengthy remediation periods that fell well below
>> expectations. Entrust gave commitments in those bugs to address the root
>> problems through process improvements, and it is concerning to see so
>> little improvement 4 years later.
>> >
>> > In light of these recent incidents, we are requesting that Entrust
>> produce a detailed report of them. This report should cover in detail:
>> >
>> > The factors and root causes that lead to the initial incidents,
>> highlighting commonalities among the incidents and any systemic failures;
>> >
>> > Entrust’s initial incident handling and decision-making in response to
>> these incidents, including any internal policies or protocols used by
>> Entrust to guide their response and an evaluation of whether their
>> decisions and overall response complied with Entrust’s policies, their
>> practice statement, and the requirements of the Mozilla Root Program;
>> >
>> > A detailed timeline of the remediation process and an apportionment of
>> delays to root causes; and
>> >
>> > An evaluation of how these recent issues compare to the historical
>> issues referenced above and Entrust’s compliance with its previously stated
>> commitments.
>> >
>> > Finally, Entrust’s report should include a detailed proposal on how it
>> plans to address the root causes of these issues. In light of previous
>> guarantees given by Entrust in 2020 to ensure speedy remediation in future
>> incidents, this proposal should include:
>> >
>> > Clear and concrete steps that Entrust proposes to take to address the
>> root causes of these incidents and delayed remediation;
>> >
>> > Measurable and objective criteria for Mozilla and the community to
>> evaluate Entrust’s progress in deploying these solutions; and
>> >
>> > A timeline for which Entrust will commit to meeting these criteria.
>> >
>> > We strongly recommend that Entrust go beyond their existing commitment
>> to offer systematic, automated solutions for effective remediation, like
>> ACME ARI and that it also include clear and measurable targets for the
>> adoption of these tools by new and existing subscribers.
>> >
>> > This report should be submitted to Mozilla dev-security-policy mailing
>> list for evaluation by the community and Mozilla, who will weigh whether
>> Entrust’s report presents a credible and effective path towards
>> re-establishing trust in Entrust’s operation. Submission should be no later
>> than June 7, 2024.
>> >
>> > We thank community members for their engagement on these issues and
>> look forward to their feedback on Entrust’s report and proposed commitments.
>> >
>> > Thanks,
>> >
>> > Ben Wilson
>> >
>> > Mozilla Root Program
>> >
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>>
>>
>>
>> --
>> Astra mortemque praestare gradatim
>>
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