In addition to the editorial review I have provided, I have significant concerns regarding the standardization of DMARC-bis. I do not expect that the working group rough consensus will necessarily agree with these concerns, but I want to state them for the working group and will probably restate them for a different audience at IETF last call.

I like to use the health care industry “safe and effective” analogy here.

## Safety

Deployment of the first iteration of DMARC has resulted in significant deployment problems, interfering with the delivery of some email from domains with a p=strict or p=quarantine policy. Examples are:

* Inappropriate use of p=reject and p=quarantine — Many domains publish restrictive policies in an effort to suppress misuse of their domain names, without regard for usage patterns. A number of online tools warn users and domain administrators that their domains aren’t fully protected if they don’t have a restricted policy, without regard to how the domain is used. Blanket policies, like DHS [BOD 18-01](https://www.cisa.gov/news-events/directives/bod-18-01-enhance-email-and-web-security), require restrictive policies for a wide range of domains (in this case for all US Government agencies). It is unlikely that the publication of DMARC-bis will rectify either of these things.

* Mailing lists — Mailing list operators, including ietf.org, have had to implement rewriting of From addresses such as u...@example.com becomes user=40example....@dmarc.ietf.org when a p=strict or p=quarantine policy is in place. This works to some extent for IETF, but there is an enormous number of mailing list operators, each of whom would need to implement address rewriting. While address rewriting is not the recommended solution, it is widely used because of the widespread inappropriate use described above.

* Receive-side forwarders — Many receive-side forwarders (e.g. alumni and organizational domains providing affinity email addresses) preserve the integrity of DKIM signatures, but not all do. This is similar to the mailing list problem, except that it is more likely to occur even with domains used only for transactional email, which is otherwise one of the more promising use cases for DMARC.

## Effectiveness

There are also factors that call into question whether DMARC(-bis) does what it purports to do (protecting the domain name), or whether that is valuable:

* Visibility of domain names — One of the justifications given for DMARC deployment is to protect the sender’s domain name: to prevent attackers from spoofing the From address of addresses in that domain. But many mail user agents (an increasing number, it seems) do not display the sender’s email address, only the friendly name. In some cases, the recipient can request to see the message header or source, but this requires specific effort and would normally only be done when the user considers a message to be suspicious. I regularly receive messages claiming to be from a bank, a well-known brand ,or even from myself, but with a completely unrelated email address. These messages pass DMARC (because the domain in the From address is controlled by them or has no DMARC record) but are still effective as potential phishing messages. These are considered out of scope for DMARC.

* Normalization of rewriting — The rewriting of From addresses described above might serve to accustom users to From address rewriting. Messages with email addresses that look like they have been rewritten can easily be used by attackers to bypass DMARC policies and reporting.

## General

In 2013, a similar protocol, ADSP [RFC5617], was [changed](https://datatracker.ietf.org/doc/status-change-adsp-rfc5617-to-historic/) from standards track to historic, citing limited use and harm caused by incorrect configuration very similar to the inappropriate use of p=reject described above. While DMARC has had considerably more use than ADSP, the harm that has been caused is correspondingly higher.

Based on the above problems, I do not think DMARC-bis should be published as a standards track document by IETF.

-Jim
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