On Wed, May 14, 2025 at 08:57:12AM -0700, Xiaohui Lam wrote:
> Based on my experience, instances of ACME account key compromise are
> extremely rare.

I don't know what you consider "rare", but I've cancelled hundreds[1] of
Let's Encrypt accounts whose private keys were publicly disclosed.  As a
percentage of all LE accounts, perhaps it's not huge, but it's certainly far
greater than the zero that would be needed to be able to claim that a
public key is a long-term stable identifier -- and that's before we
consider the need to periodically rotate keys (for whatever reason).

> I also have full confidence in Cloudflare’s robust security
> operations capability - such account key compromises are highly unlikely to
> occur internally at Cloudflare.

Since the I-D is not applicable only to Cloudflare, this argument is not
particularly persuasive.

> My suggestion is to draft the document to retain both the current account
> URI-generated suffix and add an account key-generated suffix. This would
> allow delegate operators (such as Cloudflare) to implement the optimal
> approach for their customers.

I strongly disagree with this suggestion.  Complexity is the enemy of
security, and flexibility has a nasty habit of coming back to cause
problems.

- Matt

[1] I don't keep a tally, but for a period of several years I was doing
one every couple of days -- sometimes multiple per day -- so "hundreds"
is not an unreasonable estimate.

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