Here is an additional comment:

The text mentions in the Introduction:

   In example is a resource server using verified person data
   to create certificates, which in turn are used to create qualified
   electronic signatures.

The problem is the following: the AS has no way to verify that the User has effectively authorized the RS to use the JWT Response for such a purpose. A "User Consent" phase for such a usage has not been addressed.

This concern is identified in RFC 6973 as:

5.2.3.  Secondary Use

   Secondary use is the use of collected information about an individual
   without the individual’s consent for a purpose different from that
   for which the information was collected.  Secondary use may violate
   people’s expectations or desires.  The potential for secondary use
   can generate uncertainty as to how one’s information will be used in
   the future, potentially discouraging information exchange in the
   first place.  Secondary use encompasses any use of data, including
   disclosure.

The progression of this draft is really questionable. The User has currently no way to allow or to disallow this protocol which is between a RS and an AS.  It would not be reasonable to say that this concern is outside the scope of this draft.

Denis


This draft contains a "Privacy considerations" section (Section 9).
.
The content of this section is as follows:

   The token introspection response can be used to transfer personal
   identifiable information from the AS to the RS.  The AS MUST ensure a
   legal basis exists for the data transfer before any data is released
   to a particular RS.  The way the legal basis is established might
   vary among jurisdictions and MUST consider the legal entities
   involved.

   For example, the classical way to establish the legal basis is by
   explicit user consent gathered from the resource owner by the AS
   during the authorization flow.

   It is also possible that the legal basis is established out of band,
   e.g. in an explicit contract or by the client gathering the resource
   owner’s consent.

   If the AS and the RS belong to the same legal entity (1st party
   scenario), there is potentially no need for an explicit user consent
   but the terms of service and policy of the respective service
   provider MUST be enforced at all times.

   In any case, the AS MUST ensure that the scope of the legal basis is
   enforced throughout the whole process.  The AS MUST retain the scope
   of the legal basis with the access token, e.g. in the scope value,
   and the AS MUST determine the data a resource server is allowed to
   receive based on the resource server’s identity and suitable token
   data, e.g. the scope value.

It is not believed that these explanations are useful, nor sufficient.

Talking a "legal basis" without translating legal constraints into technical constraints is not useful. Since sensitive information may be returned, the text should say that AS should/must make sure that the requesting RS is indeed
authenticated and allowed to perform this operation.

However, section 4 is only using the verb "SHOULD" whereas it should use the verb "SHALL" :

    The AS SHOULD authenticate the caller at the token introspection
    endpoint.

Talking of "an explicit user consent gathered from the resource owner by the AS" does not make sense. Either the operation is allowed or is not allowed by the RO, but there is no "RO consent".

*About **RFC 7662 (OAuth 2.0 Token Introspection)*

One might think that the important considerations have already been provided when issuing RFC 7662 (OAuth 2.0 Token Introspection)
which contains a Privacy considerations section (section 5).

The third sentence states:

    One method is to transmit user identifiers as opaque
    service-specific strings, potentially returning different
    identifiers to each protected resource.

This would mean that the response would not reflect the content of the token. Furthermore, the RS would not even be informed of such a transformation.

The last sentence even states:

    Omitting privacy-sensitive information from an introspection
    response is the simplest way of minimizing privacy issues.

In such a case, the introspection query becomes more or less useless.

What should have been said in RFC 7662 (OAuth 2.0 Token Introspection) ?

The fact that using an introspection call can be avoided and should be avoided for privacy reasons. While "in OAuth 2.0 [RFC6749], the contents of tokens are opaque to clients", it is not opaque to RSs. As soon as the RS knows the format of the access token and is able
to validate its security features, this call should be avoided.

So what should be mentioned in section 9 ?

The fact that the AS will know exactly when the introspection call has been made and thus be able to make sure which client has attempted perform an access to that RS and at which instant of time. The use of this call allows an AS to track where and when
its clients have indeed presented an issued access token.

Denis

The IESG has received a request from the Web Authorization Protocol WG
(oauth) to consider the following document: - 'JWT Response for OAuth Token
Introspection'
   <draft-ietf-oauth-jwt-introspection-response-09.txt> as Proposed Standard

The IESG plans to make a decision in the next few weeks, and solicits final
comments on this action. Please send substantive comments to the
last-c...@ietf.org  mailing lists by 2020-09-04. Exceptionally, comments may
be sent toi...@ietf.org  instead. In either case, please retain the beginning
of the Subject line to allow automated sorting.

Abstract

    This specification proposes an additional JSON Web Token (JWT)
    secured response for OAuth 2.0 Token Introspection.

The file can be obtained via
https://datatracker.ietf.org/doc/draft-ietf-oauth-jwt-introspection-response/


No IPR declarations have been submitted directly on this I-D.

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