I'd like to revive this discussion. So far we've established that the
existing "required practice" [1] is too stringent for email address
validation and needs to be changed. We can do that by removing email
addresses from the scope of the requirement as Kathleen proposed, or by
exempting the local part of the email address as I proposed earlier:

"CAs MUST NOT delegate validation of the domain name part of an email
address to a 3rd party."

We have a fairly detailed explanation from Ryan Hurst of why and how
removing the requirement entirely is beneficial, but no one else has spoken
in favor of this need. Kathleen did however point out that this requirement
doesn't appear to be the result of a thorough analysis. We have Ryan Sleevi
arguing that the process described by Ryan Hurst is insecure and thus a
reason to forbid delegation of validation of the domain name part. Pedro
Fuentes also wrote in favor of this outcome.

One thing that might help to resolve this is a more detailed description of
the weaknesses that are present in the process described by Ryan Hurst. If
we can all agree that the process is vulnerable, then it seems that we'd
have a strong argument for banning it.

- Wayne

[1]
https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices#Delegation_of_Domain_.2F_Email_Validation_to_Third_Parties


On Thu, May 23, 2019 at 12:22 PM Kathleen Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> On 5/13/19 10:24 AM, Wayne Thayer wrote:
> > The BRs forbid delegation of domain and IP address validation to third
> > parties. However, the BRs don't forbid delegation of email address
> > validation nor do they apply to S/MIME certificates.
> >
> > Delegation of email address validation is already addressed by Mozilla's
> > Forbidden Practices [1] state:
> >
> > "Domain and Email validation are core requirements of the Mozilla's Root
> > Store Policy and should always be incorporated into the issuing CA's
> > procedures. Delegating this function to 3rd parties is not permitted."
> >
> > I propose that we move this statement (changing "the Mozilla's Root Store
> > Policy" to "this policy") into policy section 2.2 "Validation Practices".
> >
> > This is https://github.com/mozilla/pkipolicy/issues/175
> >
> > I will appreciate everyone's input on this proposal.
> >
> > - Wayne
> >
> > [1]
> >
> https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices#Delegation_of_Domain_.2F_Email_Validation_to_Third_Parties
> >
>
>
> All,
>
> As the person who filed the Github issue for this, I would like to
> provide some background and my opinion.
>
> Currently the 'Delegation of Domain / Email Validation to Third Parties'
> section of the 'Forbidden Practices' page says:
> "This is forbidden by the Baseline Requirements, section 1.3.2.
> Domain and Email validation are core requirements of the Mozilla's Root
> Store Policy and should always be incorporated into the issuing CA's
> procedures. Delegating this function to 3rd parties is not permitted."
>
> Based on the way that section is written, it appears that domain
> validation (and the BRs) was the primary consideration, and that the
> Email part of it was an afterthought, or added later. Historically, my
> attention has been focused on TLS certs, so it is possible that the
> ramifications of adding Email validation to this section was not fully
> thought through.
>
> I don't remember who added this email validation text or when, but I can
> tell you that when I review root inclusion requests I have only been
> concerned about making sure that domain validation is not being
> delegated to 3rd parties. It wasn't until a representative of a CA
> brought this to my attention that I realized that there has been a
> difference in text on this wiki page versus the rules I have been trying
> to enforce. That is when I filed the github issue.
>
> I propose that we can resolve this discrepancy for now by removing "/
> Email Validation" from the title of the section and removing "and Email"
> from the contents of the section.
>
> Unless we believe there are significant security reasons to add our own
> S/MIME required/forbidden practices at this time, my preference is to
> wait for the CA/Browser Forum to create the S/MIME Working Group, and
> for that group to identify the S/MIME baseline requirements. Then we can
> add policy and required/forbidden practices based on the S/MIME BRs
> provided by that group.
>
> I do realize that my proposal is unfair to CAs who have been diligently
> following this section of this wiki page. Your diligence is appreciated,
> and your contributions to this discussion will also be appreciated.
>
> Thanks,
> Kathleen
>
>
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>
> _______________________________________________
> dev-security-policy mailing list
> dev-security-policy@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
>
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