Ryan,
I won't speak for Doug, but what I see is that any change at this point will require every CA to make a lot of code changes to a lot of systems.
 - the core CA system that actually provisions the certs
- the suport systems that are used for certificate verification which have had the current timeframes coded in - the retail systems which are used to sell the certificates to the customers

Not to mention communications to partners and major stakeholders of the upcoming change, and their inevitable surprise and unhappiness when the changes actually go into effect because they failed to pay attention. Another bad customer experience, even though in this example, one of their own making.

IMO, Jeremy's proposal of option 1a gives CAs zero incentive to support all of the above. I'm aware of and agree with the security incentive a shorter max validity offers, but as you are well aware, end users/customers don't LIKE security, unless it comes at ZERO cost to them in time, money, inconvenience, etc. If that wasn't true, all the browsers would be doing revocation checks on every certificate encountered. I'm not certain my proposal of 27/27 max validity/revalidation is enough incentive to get support for it, but at least it does offer some incentive.

-Rich


On 3/30/2016 11:56 AM, Ryan Sleevi wrote:

Doug,

Forgive my ignorance, but could you perhaps expand on this, and explain a bit more about the challenges your organization would face?

From the browser perspective, reducing validity times and revalidation times is a big win for security and the ability to change. The ability to make changes one year sooner is a HUGE win. I can understand and appreciate that you may value that increased security differently, but where I would like to understand better is what impact this would have from the CAs side, and why this would be undesirable.

To that end, would you be willing to explain in more detail what would have to happen on the CA's side to bring this in? Can you "sell me" on the difficulty, by perhaps providing more concrete explanations of the changes necessary, and not just the abstract categories? My ideal response to such an email from you would ideally be "Wow, that's so much, I didn't realize" - so can you fill in that blank and help me have that reaction?

Ultimately, the goal is to better understand the concrete concerns and objections, as well as have a better understanding of the overall challenges, so that if and when we revisit this topic, we can make sure to fully consider the impact and perhaps explore solutions.

The challenge that I have with your current response is that it doesn't share enough detail to really see if there is any room for changes or compromise, nor does it really help form a picture other than "This is hard because I say it's hard," and I suspect there's much more subtlety and nuance than the broad stroke I just painted it as.

On Mar 30, 2016 9:41 AM, "Doug Beattie" <[email protected] <mailto:[email protected]>> wrote:

    Jeremy,

    I'm also against making any changes.  I don't see the value of
    this change exceeding all the work on communications, system
    updates and operational procedure changes needed to make this happen.

    Doug

    *From:*[email protected]
    <mailto:[email protected]>
    [mailto:[email protected]
    <mailto:[email protected]>] *On Behalf Of *Rich Smith
    *Sent:* Wednesday, March 30, 2016 12:32 PM
    *To:* [email protected] <mailto:[email protected]>
    *Subject:* Re: [cabfpub] Certificate validity periods

    Jeremy,
    I'm not sure Comodo would support any change at this point, but if
    we were to change I'd like to propose, let's call it 1c;
    Set all max validity to 27 months; Require re-validation for all
    at 27 months.

    I'm against your proposal of 1a for the same reasons I don't like
    27/13 for EV  It puts us in position of having to redo validation
    of a replacement request by the customer.  In this case, the
    customer would get the DV or OV for 27 months, be able to replace
    at will, renew the cert for an additional 27 months, but be
    subject to revalidatiion half way through the 2nd when trying to
    get a replacement/re-issuance.  This is bad enough with EV
    already, and I'm very much against extending it to OV/DV.  If we
    can't find a reasonable path to match up the re-validation
    requirement with max validity then I'm against making any changes.

    >From the customer perspective, they expect to have to jump
    through hoops at the point of placing a new order.  We don't
    generally get push back on that. What they don't expect, and what
    it is very difficult to make them understand is having to jump
    through the hoops again during the validity period of the same
    order.  The customer doesn't understand these requirements and it
    causes a bad customer experience, for which they blame the CA.

    -Rich

    On 3/30/2016 11:04 AM, Jeremy Rowley wrote:

        Hi everyone,

        I'd like to resurface the certificate validity period
discussion and see if there is a way to move this forward. I'm still keen on seeing a standardized maximum validity
        period for all certificate types, regardless of whether the
        certificate is DV, OV, or EV. I believe the last time this was
        discussed, we reached an impasse where the browsers favored a
        shorter validity period for OV/DV and the CAs were generally
        supportive of a longer-lived EV certificate (39 months). The
        argument for a shorter validity period were 1) encourages key
        replacement, 2) ensures validation occurs more frequently, 3)
        deters damage caused by key loss or a change in domain
        control, and 4) permits more rapid changes in industry
        standards and accelerates the phase-out of insecure practices.
        The argument for longer validity periods: 1) customers prefer
        longer certificate validity periods, and 2) the difficulty in
        frequent re-validation of information.

        So far, there seems to be two change proposals with a couple
        of variations:

        1)Set all certificate validity periods to no more than 27 months

        a.Require re-validation of information for OV/DV certificates
        at 39 months OR

        b.Require re-validation of information for all certs at 13 months

        2)Set all certificate validity periods to 39 months

        a.Require re-validation every 13 months

        b.Require re-validation of information for OV/DV certificates
        at 39 months

        What are the objections to 1a? With all the automated
        installers abounding, 1a seems to capture the simplicity and
        customer convenience of 39 months with the advantages of
        shorter-lived certs. Who would oppose/endorse a ballot that
        does one of these?

        Jeremy




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