I don't think that is true.  Remember for OV/IV/EV certificates, the
Subscriber is the natural person or Legal Entity identified in the
certificate Subject.  If the Subscriber is using the certificate on a
CDN, it is probably better to have the CDN generate the key rather
than the Subscriber.  The key is never being passed around, in PKCS#12
format or otherwise, even though the Subscriber isn't generating the
key.

On Tue, May 15, 2018 at 9:17 PM, Tim Hollebeek via dev-security-policy
<dev-security-policy@lists.mozilla.org> wrote:
> My only objection is that this will cause key generation to shift to partners 
> and
> affiliates, who will almost certainly do an even worse job.
>
> If you want to ban key generation by anyone but the end entity, ban key
> generation by anyone but the end entity.
>
> -Tim
>
>> -----Original Message-----
>> From: dev-security-policy [mailto:dev-security-policy-
>> bounces+tim.hollebeek=digicert....@lists.mozilla.org] On Behalf Of Wayne
>> Thayer via dev-security-policy
>> Sent: Tuesday, May 15, 2018 4:10 PM
>> To: Dimitris Zacharopoulos <ji...@it.auth.gr>
>> Cc: mozilla-dev-security-policy 
>> <mozilla-dev-security-pol...@lists.mozilla.org>
>> Subject: Re: Bit encoding (AW: Policy 2.6 Proposal: Add prohibition on CA key
>> generation to policy)
>>
>> I'm coming to the conclusion that this discussion is about "security 
>> theater"[1].
>> As long as we allow CAs to generate S/MIME key pairs, there are gaping holes
>> in the PKCS#12 requirements, the most obvious being that a CA can just
>> transfer the private key to the user in pem format! Are there any objections 
>> to
>> dropping the PKCS#12 requirements altogether and just forbidding key
>> generation for TLS certificates as follows?
>>
>> CAs MUST NOT generate the key pairs for end-entity certificates that have an
>> EKU extension containing the KeyPurposeIds id-kp-serverAuth or
>> anyExtendedKeyUsage.
>>
>> - Wayne
>>
>> [1] https://en.wikipedia.org/wiki/Security_theater
>>
>> On Tue, May 15, 2018 at 10:23 AM Dimitris Zacharopoulos <ji...@it.auth.gr>
>> wrote:
>>
>> >
>> >
>> > On 15/5/2018 6:51 μμ, Wayne Thayer via dev-security-policy wrote:
>> >
>> > Did you consider any changes based on Jakob’s comments?  If the
>> > PKCS#12 is distributed via secure channels, how strong does the password
>> need to be?
>> >
>> >
>> >
>> >
>> >
>> > I think this depends on our threat model, which to be fair is not
>> > something we've defined. If we're only concerned with protecting the
>> > delivery of the
>> > PKCS#12 file to the user, then this makes sense. If we're also
>> > concerned with protection of the file while in possession of the user,
>> > then a strong password makes sense regardless of the delivery mechanism.
>> >
>> >
>> > I think once the key material is securely delivered to the user, it is
>> > no longer under the CA's control and we shouldn't assume that it is.
>> > The user might change the passphrase of the PKCS#12 file to whatever,
>> > or store the private key without any encryption.
>> >
>> >
>> > Dimitris.
>> >
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>
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