Hi Wayne,

I’d like to better understand your worry and perhaps interpretation of BR 
6.1.1.3(4) and 4.9.1.1(3,4,16). Just to restate for my benefit, the concern is 
that: IF we interpret Tim’s message regarding the testkeys draft as qualifying 
the keys present in the draft as “[All] CAs [subscribed to the Servercert-wg 
list being] made aware that [a future] Applicant’s Private Key has suffered a 
Key Compromise….” THEN, in a similar situation, any servercert-wg member could 
share any number of compromised keys here and, theoretically, bloat (with no 
upper bounds) the set of known compromised keys a CA has to retain and check in 
order to reject certificate requests as needed to meet the requirements of 
6.1.1.3 WHILE also not necessarily increasing the meaningful security provided 
by the BRs. Is that correct?
As a concrete example (an extreme I could imagine), someone could generate, and 
potentially delete, 100 or 100,000,000,000 keypairs easily (for a value of 
“easily” most associated with effort rather than time or resources), share a 
CSV, or even just pointer to a repository/document, with the Servercert-wg, and 
(if interpreted per your worry) cause a bunch of keys never intended to be used 
for actual certificate issuance to be forever part of a set of keys which all 
CAs must check every received certificate request against.

Notable to this worry, I think, is that nothing about the language in in the 
BRs today indicates to me that Tim’s message or the above, somewhat silly, 
scenario would not be interpreted to qualify as a reason to reject those 
associated keys. That is, if a CA subscribed to this mailing list and 
conforming to the BRs, issued a certificate to a key in the testkeys draft 
after July 4, 2023, it seems that the BRs would consider that a misissuance as 
there’s no limitation or specification regarding what (or whether) any specific 
bar is met in order to constitute “the CA [being] made aware”. 4.9.3 I think 
comes quite close, but stops short of saying something like “For the purposes 
of requirements in 4.9.1.1, 4.9.1.2, and 6.1.1.3, the CA MAY require a 
Certificate Problem Report to be submitted in order to constitute being made 
aware of reasons to reject certificate requests or revoke certificates.” which 
I think would remove the current ambiguity regarding what needs to happen in 
order for a CA to need to begin rejecting certificate requests for compromised 
keys. (Note, I’m not saying this change is a good or well-thought-out idea, 
just what came to mind as one option to increase clarity in a way that would 
address the worry raised.)

This is separate, in my mind, to any potential interpretation that would expect 
CAs to go out and look for compromised keys elsewhere. “Looking" implies to me 
a proactive effort, whereas “made aware” is much more passive and would 
seemingly include any receipt of information by the CA (or its official 
representatives?). More to the point, I don’t see any implication that CAs 
should be looking for compromised keys in the current BR text, which hopefully 
helps with part of the worry (though adding something like that as a 
requirement has been discussed before, iirc, especially in the context of 
pwnedkeys.com <http://pwnedkeys.com/> and I could see that, and related topics, 
coming up again with 
https://www.ietf.org/archive/id/draft-mpalmer-key-compromise-attestation-00.txt).

While I don’t foresee near-term, major, and negative impact from my 
interpretation of the BRs, I do think we can maintain the intent of the 
requirement without leaving it as open as a rough analogue to a zip bomb. While 
I proposed something purely for illustration above, I’ve also filed 
https://github.com/cabforum/servercert/issues/442 to track this if there’s 
further interest in ensuring the BRs could address this worry.

As always, please let me know if I’ve missed some crucial detail or interaction 
here that’s led me to an erroneous conclusion on the topic. Cheers!
-Clint

> On Jul 7, 2023, at 3:13 PM, Wayne Thayer via Servercert-wg 
> <servercert-wg@cabforum.org> wrote:
> 
> Thanks for sharing this Tim.
> 
> I want to comment on the statement that CAs should blocklist the keys 
> published in this RFC. Doing that may very well be helpful to the CA and 
> their customers, but I do not believe it is a requirement set forth by the 
> CAB Forum or root store policy.
> 
> Prior discussions on this topic have not resulted in requirements beyond the 
> clarification of BR 6.1.1.3(4): "The CA has previously been made aware that 
> the Applicant’s Private Key has suffered a Key Compromise, such as through 
> the provisions of Section 4.9.1.1;". My worry is that we will begin 
> interpreting "has previously been made aware" as inclusive of keys published 
> in a RFC that Tim sent to the mailing list, without any bounds or guidance on 
> where else CAs must look for compromised keys (e.g. scanning online databases 
> and software packages). I don't necessarily intend to start a big debate 
> about this, but rather just hope to avoid confusion about the current 
> requirements and expectations.
> 
> - Wayne
> 
> On Wed, Jul 5, 2023 at 11:43 AM Tim Hollebeek via Servercert-wg 
> <servercert-wg@cabforum.org <mailto:servercert-wg@cabforum.org>> wrote:
>> Just wanted to make sure CAs are aware of the Gutmann testkeys draft, which 
>> will be an RFC soon.  CAs should add these keys to the list of keys they 
>> refuse to issue certificates for (because the private keys have been 
>> disclosed publicly).
>> 
>> -Tim
>> 
>> -----Original Message-----
>> From: secdir <secdir-boun...@ietf.org <mailto:secdir-boun...@ietf.org>> On 
>> Behalf Of Melinda Shore via Datatracker
>> Sent: Tuesday, July 4, 2023 8:33 PM
>> To: sec...@ietf.org <mailto:sec...@ietf.org>
>> Cc: draft-gutmann-testkeys....@ietf.org 
>> <mailto:draft-gutmann-testkeys....@ietf.org>; last-c...@ietf.org 
>> <mailto:last-c...@ietf.org>
>> Subject: [secdir] Secdir last call review of draft-gutmann-testkeys-04
>> 
>> Reviewer: Melinda Shore
>> Review result: Ready
>> 
>> The use of the plural "PKCs" surprised me a bit, but that's a taste question 
>> rather than a substantive one.  I've verified that the test keys in the 
>> document are usable and that the struct representation produces the same 
>> keys as the PEM encodings in the draft (there are some unsurprising 
>> differences in the PEM encoding of the keys by different libraries, but the 
>> actual contents are identical).
>> 
>> I recently retired from a CA and when the -00 version of the draft was 
>> uploaded we had some discussion of whether or not these were keys that we'd 
>> need to add to the "badkeys" list (i.e. keys for which certificates can't be 
>> issued), and since the document is going to RFC it's now clearly the case 
>> that we'd need to.
>>  It may be worth sending a heads-up to the CA/B Forum about that.  It's also 
>> common now to see test vectors included in protocol specifications (or 
>> adjacent to protocol specifications) and I wonder if it's possible to 
>> encourage document authors to use these keys where appropriate.
>> 
>> Anyway, this is a tidy, well-written document that does exactly what it sets 
>> out to do, and it's ready.
>> 
>> 
>> _______________________________________________
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>> https://www.ietf.org/mailman/listinfo/secdir
>> wiki: https://trac.ietf.org/trac/sec/wiki/SecDirReview
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