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Hi everyone, This email is intended to gather public and browser feedback on how we are handling the transitioning Verizon's customers to DigiCert and share with everyone the plan for when all non-DigiCert hosted sub CAs will be fully compliant with the BRs and network security guidelines. Primarily, this letter addresses when all issuing CAs previously held by Verizon will be covered by an unqualified audit and how we are responding to the sub CAs that issued SHA1 certificates. We are looking forward to the browser and public feedback on how to handle the non-compliant cross-signs and insight on how the public views our transition progress and planned completion dates. Background Prior to presenting the plan for remediation, I thought I'd share a bit about our progress with migrating Verizon customers. About a year ago in July, DigiCert closed an agreement with Verizon where DigiCert took ownership of three publicly-trusted Verizon root certificates. These certificates are the Verizon Global Root CA, the Baltimore CyberTrust Root CA, and the Verizon Root CA. There were many reasons the acquisition made sense, including acquisition of a root that had cross-signed DigiCert for many years. The ubiquity of the Verizon roots is wide-spread, which meant a lot of CAs like to cross-sign with them. Another significant reason for the acquisition was an attempt to improve the CA industry. After watching the issuance of wildcard EV certs, non-compliant subordinate CAs, and certs with poor profiles, we made a conscious decision to purchase these roots with the intention of migrating them to more complaint system. We felt that helping these CAs get to the point of regular audits and best practices would raise the quality of the entire industry. Prior to the acquisition, we were made aware of several potential non-compliances by Verizon's customers. We worked closely with Verizon to clean up many of the Sub CAs, including revoking CAs that would never be compliant with the requirements and attempting to technically constrain others. Sub CAs were revoked because they either didn't have an audit, were unresponsive to communication, or couldn't control their issuance. Verizon was a great partner and took a very proactive approach in removing CAs that were not actively working towards compliance. Unfortunately, the age of the roots and large number of cross-signs led to a lot of missing paperwork and certain issues in identifying which CAs were covered by audits. Prior to closing we believed there were approximately five technically constrained sub CAs and around 20 unconstrained sub CAs. Turns out there were actually more than 200, each with various levels of compliance. Most of these Sub CAs operated under the Baltimo re Cybertrust root, which was created in 2000. To their credit, Verizon revoked 48 of the issuing CAs prior to DigiCert's acquisition of the roots. Unfortunately, this left around 150 for our small team to work through. Although the endeavor was daunting, Ben Wilson and others worked to gather audit reports, email customers about compliance dates, monitor certificates issued, and revoke non-compliant customers. Verizon was very good at assisting us in these efforts. This information is now recorded in the Mozilla database and continuously updated as the information changes. Transition Process After our operational acquisition of the roots (which occurred the last part of September, 2015), we identified 15 expired issuing CAs, 70 revoked sub CAs, 131 audited sub CAs, and 36 where the status was unknown. Since then, we've revoked 25 issuing CAs and assisted others with technical constraints, exodus from the Omniroot cross-signing program, or obtaining audits. Of the existing sub CAs, about half remain operational and are either audited or technically constrained. The other half are either winding down or have been revoked. All revoked certificates were disclosed to Mozilla via Salesforce and should be part of OneCRL. Issuing CAs There are only a handful of non-audited sub CAs remaining (see https://crt.sh/mozilla-disclosures#disclosureincomplete). We have a plan for each of them that we'd like to share with you. We welcome both browser and public feedback. This is, of course, simply a proposal on how to finish the transition and provide transparency into where we are at. We are certainly willing to modify the plan as needed to further online security and meet the requirements of the root store operators. The seven companies listed below are responsible for the remaining unaudited sub CAs: 1. ABB has three unaudited issuing CAs. ABB didn't undergo an audit earlier this year on the assumption that their sub CAs were technically constrained. Unfortunately, the constraints weren't properly implemented, a fact that escaped notice until Rob Stradling's excellent tool exposed a deficiency a few months ago in how Verizon issuance process. Although Verizon restricted domain names and IPv4 IP addresses, the CAs could still issue for the IPv6 space. Despite promptly replacing the certificates after discovering the gap, we haven't revoked the issuing CAs. Right now, ABB is actively working to transition its servers to the new, properly-constrained certificates. We expect the transition to complete by the end of December 2016. We are revoking the issuing CAs as the migration completes and expect all of the ABB non-compliant issuing CAs to be revoked on January 5th. No new certs are being issued from the faulty issuing CAs. 2. Similar to ABB, Verizon created two technically constrained issuing CAs for Bechtel. Like ABB, Verizon failed to restrict IPv6 issuance for each of the issuing CAs. Bechtel is actively migrating the remaining 785 certificates to properly constrained issuing CAs. The migration process will complete at the end of December, after which the non-conforming issuing CAs will be revoked. They are included in our January 5th revocation plan. This will also revoke the three issuing CAs created further down in the chain. 3. Dell also thought they were technically constrained. Similar to ABB and Bechtel, the restriction was inadequate. Fortunately, Dell isn't using the issuing CAs and doesn't require migration. We've previously revoked four issuing certificates (Bug 1279066) but missed one during the process. We plan to immediately revoke the remaining issuing CA and all CAs subordinate to the issuing CA. 4. While Certipost is hosted by Verizon's internal infrastructure, the Verizon WebTrust audit letter did not specifically identify the Certipost CAs as audited. DigiCert has been in the process of revoking these CAs but there is some confusion about the effects of the revocation. Apparently the certificates are used for air traffic control in Europe and there is a fear that revoking the intermediate may cause planes to fall out of the sky. After trying to sort out this mess and giving Certipost time to transition, we've decided to revoke the issuing certificates the last week of November. We believe there are over 400 outstanding certificates that will be affected. 5. Postecom refused an audit and decided to exit operation of a CA. We have not yet revoked their issuing CAs in order to give them time to migrate to a different CA infrastructure. They asked that we keep the issuing CAs active until December 31, 2016 to complete the migration. Although they have worked on migrating certs, Postecom still has 1185 certificates to migrate in the next two months. The issuing CAs are scheduled for revocation on January 5th. 6. Vodafone completed a Webtrust audit this year. Unfortunately, we found out that the audit has qualifications. The audit report hasn't issued yet but should later in November. Once the audit report issues, we will provide a copy of the report for evaluation. We've been told that the qualifications are related to the network security guidelines. They probably also include the SHA1 issuance, although we haven't been told that directly. Vodafone is currently designing and building a new CA infrastructure that will house all of their operations. To ensure compliance, we are requiring the new infrastructure to undergo a point-in-time audit in December. We are also requiring a full audit on their issuance processes at the start of next year. A full, non-qualified audit report is expected by March 31, 2016. Although this is well past the compliance date, we are sympathetic to Vodafone as they have been actively working towards compliance. They also have 4,580 public facing SS L certs makes revocation tricky. They issue a lot of client certificates from these sub CAs where revocation could have a potentially devastating effect on telecommunications. Because of the large impact of revocation and how hard Vodafone is working to migrate, we'd like permission for them to comply by March 31, 2017, assuming serious issues are not uncovered by the audit report and that the December and January audits pass unqualified. 7. The Belgium government is our biggest challenge in migrating Verizon customers. With over 20 issuing CAs, Belgium has the largest outstanding non-compliant infrastructure. The operators have also claimed that revoking their issuing CAs is illegal (in Belgium). The government is using the issuing CA for creating personal identification (e-ID) cards throughout the country. The Belgium government has dictated that they set the rules, not us. Although the Belgium government does not have an audit yet, Verizon has represented that the issuing CAs are hosted in the Verizon infrastructure and are potentially covered by the Verizon audit. We've asked Verizon to provide an updated audit report showing coverage of the Belgium issuing CAs by December 1, 2016. If the report is not delivered by December 1, 2016, we plan to immediately revoke the issuing CAs. If, for whatever reason, we are unable to revoke the issuing CAs at that time, we would certainly not object to the brows ers distrusting the issuing CAs issued to Belgium. Resolving these remaining seven issues will, bring all Verizon's sub CAs into compliance with the audit requirements by March 31, 2017. As of January 2017, all sub CAs operated under the Verizon umbrella will have a non-qualified audit with the exception of Vodafone, which will have a non-qualified point-in-time audit by then. SHA-1 Although by March 31, 2017, all former Verizon customers will comply with the audit portion of the BRs, experience has recently shown that strict compliance of profile requirements is more difficult to enforce. Such is the case of the SHA1 certificates issued by Nets Norway, Siemens, and Vodafone. Nets Norway and Siemens were both ETSI audited while Vodafone opted for a Webtrust audit. Shortly after the Verizon transaction, we sent a statement to each CA announcing the acquisition and our expectation of strict compliance with the BRs and network security requirements. On January 27, 2016, we sent another email to all CAs that reiterated the need for strict adherence to standards and requirement for CAs to update their infrastructure as needed to maintain an unqualified audit. The specifically stated that issuance of internal name certificates and SHA1 certificates is strictly forbidden. Nets Norway, Vodafone, and Siemens all received a copy of this email. As all the sub CAs should have been aware of the requirements in 2015, were reminded this year, and had audits of their infrastructure, we are very disappointed by the recently discovered SHA-1 issuance. We've contacted each of the sub CAs asking for an explanation on what happened and why their infrastructure wasn't sufficient to prevent SHA1 issuance. Of the SHA1 cert issuers, Vodafone is the only sub CA that responded by providing a timeline for compliance, information about how they are migrating to new CA (which we already knew), and a plan going forward to undergo an audit and make sure technical constraints are active to prevent additional SHA1 certificates. Siemens replied that they are revoking the SHA1 certificates, that issuance was a mistake, and that they are taking action to prevent additional mis-issuance. However, the specifics of their plan are vague (other than providing operational training to prevent reoccurrence). For both Vodafone and Siemens, this is their first offense in mis-issuing a SHA1 certificate, and we'd ask for leniency. We do recognize that this is a serious concern and can revoke the issuing CAs if the action is decided necessary. For full disclosure, Siemens is transitioning away from the Verizon root certificate to another CA. We are only maintained the validity of their cross-sign in a g ood faith effort to help them complete the transition. We were planning to revoke the issuing CAs early next year (January 5th) once the transition is completed. The final CA is Nets Norway. Unlike the other two issuing CAs, Nets Norway issued a SHA1 certificate earlier this year. Although Nets Norway promptly revoked the certificate and provided verbal assurances that SHA1 issuance would be restricted, the company obviously failed to take adequate measures. We informed Nets Norway that we are revoking their issuing CA later this month. We haven't revoked them yet because we wanted to complete the incident report first and allow public comment before finalizing the decision. Our investigation of Verizon's, Postecom's, and Telecom Italia's issuance of a SHA1 certificate is ongoing. As mentioned above, Postecom is scheduled for revocation. Our plan for now is to keep the current revocation schedule for Postecom as the SHA1 issuance occurred twice during January. We haven't formed a plan for Verizon or Telecom Italia yet and are waiting to hear back from their representatives. Verizon issued a single certificate back in January. Telecom Italia issued three in early January and February. Each of these incidents were only recently discovered by DigCert. We've since added an active monitor to crt.sh to alert our compliance team if a SHA1 certificate issues. Conclusion Hopefully this helps explain the status of the Verizon transition and the recent SHA1 incidents. We are still collecting information from the three issuing sub CAs about what happened, but I hope this is enough to provide transparency and make a decision on how to proceed. Despite the difficulties in bringing these customers into compliance, we still think the Verizon transaction was a good move from a compliance perspective. Helping these sub CAs identify problems and improve their processes has been an enlightening experience and given us insight on some of the difficulties other CAs may face in complying with the BRs. The process has been interesting exercise in helping others make remediation plans and trying to accelerate what feels like a slow-moving project. Despite the long nights, headaches, and frustrations, I think we've been successful in our original goal of improving the security ecosystem. I'm also very pleased that the end of the transition is almost here! We appreciate your feedback and look forward to your comments. Sincerely, Jeremy _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
