Duly noted. Thanks!

On Tuesday, November 9, 2021 at 1:03:22 PM UTC-8 aa...@letsencrypt.org 
wrote:

> Hi Kathleen,
>
> I believe that the first item proposed to be not-in-scope should be at 
> least partially-in-scope. In particular, a request to revoke a certificate 
> with reason "keyCompromise" is not necessarily the same as a demonstration 
> of key compromise. I believe that future policies should assume that 
> reasonably-informed subscribers take the correct action, yes, but we should 
> be careful not to mandate that a CA take any additional actions when they 
> receive a keyCompromise revocation request that is not accompanied by a 
> demonstration of said compromise.
>
> Aside from that, I think that the proposed parameters of the discussion 
> are very good, and I look forward to continuing in this vein!
> Aaron
>
> On Mon, Nov 8, 2021 at 2:38 PM Kathleen Wilson <kwil...@mozilla.com> 
> wrote:
>
>> All,
>>
>> As you know, there are currently many limitations in regards to the 
>> revocation reason codes for TLS certificates. I would like to have a few 
>> discussions here in MDSP 
>> <https://groups.google.com/a/mozilla.org/g/dev-security-policy> to try 
>> to resolve some of the limitations by addressing them with updates to 
>> policy, audit criteria, tools, documentation, and code.
>>
>> I propose that we tackle this by having a series of discussions as 
>> follows:
>>
>>    1. Previous discussion 
>>    
>> <https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/t-HeK2qTyeg/m/FZJB0M8sAwAJ>:
>>  
>>    Why we/Mozilla want to improve revocation codes for TLS certificates: 
>>    
>> https://wiki.mozilla.org/CA/Revocation_Checking_in_Firefox#Revocation_Is_Important
>>    2. This discussion: Set expectations about what we want to accomplish 
>>    in upcoming updates to Mozilla's Root Store Policy by identifying what is 
>>    in and what is out of scope at this time.
>>    3. Next discussion: Determine which revocation reason codes 
>>    should/should-not be used for TLS certificates, and define the situations 
>>    during which certain revocation codes must be used.
>>    4. Future Discussion: Determine which revocation reasons must be made 
>>    available to subscribers and others by CA tools and documentation.
>>    5. Future Discussion: Identify conditions under which CAs would be 
>>    required to communicate with the certificate subscriber before revoking 
>> the 
>>    certificate if the revocation request did not originate from the 
>> subscriber.
>>    6. Future Discussion: Finalize new text to be added to Mozilla’s Root 
>>    Store Policy, and determine effective dates.
>>    
>> I propose that the following limitations be IN-SCOPE of these discussions 
>> and the policy updates:
>>
>>    1. There are no policies specifying when certain revocation codes 
>>    should or should not be used
>>    2. Some CAs do not use revocation reason code at all for TLS 
>>    end-entity certificates
>>    3. Some CAs use the same revocation code for every revocation
>>    4. CAs can revoke certificates without informing their certificate 
>>    subscribers about the revocation beforehand
>>    5. We do not have confidence that revocation codes are being used 
>>    properly, and there is little incentive for CAs to use correct revocation 
>>    codes
>>    6. There are no policies specifying the information that CAs should 
>>    provide to their certificate subscribers about revocation reasons
>>    
>> The following limitations are PARTIALLY-IN-SCOPE in regards to 
>> determining what information CAs must provide to their customers, that CAs 
>> must provide revocation interfaces in which the revocation reasons are 
>> clear, and that CAs must ensure customers understand their obligations to 
>> protect the private key throughout the certificate validity period.
>>
>>    1. Certificate subscribers do not understand what each revocation 
>>    reason code means, so they may provide the wrong value
>>    2. It is difficult for certificate subscribers to figure out how to 
>>    properly add the revocation code, or they have to call the CA’s customer 
>>    service to get it set correctly
>>    3. The reason for revocation can change over time; e.g. initially be 
>>    for cessationOfOperation, but later have the private key compromised
>>    
>> I propose that the following limitations are NOT-IN-SCOPE of these 
>> discussions and policy updates:
>>
>>    1. CAs are dependent on the certificate subscriber to report the 
>>    correct revocation reason.
>>       - Policies should be written about CA actions, and have to assume 
>>       that the certificate subscriber takes the correct action when they are 
>>       reasonably informed about it.
>>    2. The set of revocation reason codes are insufficient for the web 
>>    PKI, Reference: https://unmitigatedrisk.com/?p=583
>>       - Updating RFC 5280 would be difficult and take an indefinite 
>>       amount of time. On the other hand, we have complete control of 
>> Mozilla’s 
>>       Root Store Policy.
>>    3. CAs can be compelled to revoke (e.g. by a court).
>>    4. Once a certificate has been used with a client, the certificate 
>>    can persist in the browser even after it has been revoked.This can 
>> happen, 
>>    for example, if the browser end-user has installed a Service Worker, 
>>    stashed code in Indexed DB, polluted the user's disk cache, exfiltrated 
>>    cookies that they can still use, etc). So even after a site has revoked a 
>>    certificate, there is no guarantee of what state the end-users are in.
>>       - Somehow the website operator would have to use ClearSiteData to 
>>       force-erase everything for their users, but it's unclear how long the 
>>       website operator would have to do this, because it could be weeks 
>> before 
>>       each user revisits the site.
>>       - Our intent is to improve the current ecosystem, and we 
>>       acknowledge that the potential for situations like this still exists.
>>       
>>
>> I will greatly appreciate your thoughtful and constructive feedback on 
>> this.
>>
>> Thanks,
>> Kathleen
>>
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>>
>

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