Hi all,

Thanks for the feedback.

We'll pursue this further
<https://github.com/cabforum/servercert/issues/580> within the SCWG.

- Ryan

On Wed, Apr 2, 2025 at 11:24 AM Jeremy Rowley <[email protected]> wrote:

> I agree with Aaron. CAA failures should be treated as requiring a 24 hour
> revocation deadline, but the current language does not support this. We
> should fix it by changing 4.9.1.1 to include CAA checking failures as a
> reason for 24 hour revocation.
>
> On Tue, Apr 1, 2025 at 12:32 PM 'Aaron Gable' via CCADB Public <
> [email protected]> wrote:
>
>> Thanks for bringing this conversation to a better venue!
>>
>> For the record, I agree that failure to properly check CAA *should*
>> result in a 24-hour revocation timeline. CAA checking is a critical, and
>> easily automated, part of the issuance process.
>>
>> However, I disagree that this is what the BRs actually say today.
>>
>> A failure to conduct CAA does not fall under BRs 4.9.1.1(2), because the
>> Subscriber has not notified the CA of anything. This is especially true in
>> cases where the CA discovers that they have been failing to correctly check
>> CAA, but it turns out that correctly checking CAA wouldn't have resulted in
>> a different issuance decision.
>>
>> And as I argued in the Bugzilla ticket, a failure to check CAA does not
>> fall under BRs 4.9.1.1(5) because CAA is part of the issuance process, not
>> part of the validation of domain authorization or control.
>>
>> In that Bugzilla ticket, Amir said:
>> > From my interpretation of the BRs, domain issuance can be summed up as:
>> "Always issue the certificate, except in ${list_of_scenarios}".
>>
>> I strongly disagree with this interpretation. The BRs, in my opinion, say
>> that a CA should *never* issue unless validation has succeeded. I think it
>> is relevant and accurate to think of the BRs as first a positive filter
>> (DCV, identity validation) that must be satisfied before a CA can even
>> consider issuing, followed by a set of negative filters (caa, linting,
>> mpic) that may still prevent issuance but could never allow issuance in the
>> first place.
>>
>> Amir also said:
>> > CAA (Certificate Authority Authorization) should be considered in the
>> authorization part of domain authorization and control.
>>
>> Unfortunately this interpretation is ahistorical. The "authorization" in
>> CAA is about whether the CA is authorized to issue for the domain. The
>> "authorization" in "domain authorization and control" is about whether the
>> *applicant* is authorized to request issuance for the domain. These are
>> fundamentally different things, despite using the same word.
>>
>> Potential changes to the BRs that would resolve this apparent gap include:
>> - changing 4.9.1.1(2) to say "the CA learns that the request was not
>> authorized", rather than requiring proactive notification (though this has
>> the disadvantage that CAA failures now have two different revocation
>> timelines, depending on whether the CA failure to check a record that
>> happened to allow issuance vs one that happened to disallow it)
>> - changing 4.9.1.1(5) to list CAA alongside DCV
>> - adding a new list item to 4.9.1.1 explicitly addressing CAA
>>
>> Aaron
>>
>> P.S. apologies that this is likely my only contribution to this thread,
>> as I leave for two weeks of vacation today.
>>
>>
>> On Tue, Apr 1, 2025, 08:20 'Amir Omidi (aaomidi)' via CCADB Public <
>> [email protected]> wrote:
>>
>>> Thank you for putting this up CRP.
>>>
>>> Based on the commentary I've seen through
>>> https://bugzilla.mozilla.org/show_bug.cgi?id=1951415, I do think that
>>> we should be treating violations that happen in the path of issuance as a
>>> misissuance that requires a 24 hour revocation window. I've always used,
>>> and interpreted CAA as a security measure. This is also asserted in the
>>> RFC <https://datatracker.ietf.org/doc/html/rfc8659#section-5> itself:
>>> "CAA records assert a security policy that the holder of an FQDN wishes to
>>> be observed by Issuers."
>>>
>>> > We recognize that a request not being authorized and issuance not
>>> being authorized are indeed distinct, but from our view they appear to
>>> communicate the same conclusion in that from the subscriber’s perspective
>>> issuance should not have taken place.
>>>
>>> Agreed, I don't think reinterpreting this as anything else is useful for
>>> anyone (including the CAs). Having a unified approach to revocation
>>> simplifies operations by removing the judgement that is necessary today to
>>> ask "is this a 24 hour or 120 hour event?"
>>>
>>> Cheers,
>>> Amir
>>> On Tuesday, April 1, 2025 at 11:02:07 AM UTC-4 Ryan Dickson wrote:
>>>
>>>> Hi all,
>>>>
>>>> We were curious for community feedback on the applicability of TLS BR 
>>>> revocation
>>>> timelines
>>>> <https://cabforum.org/working-groups/server/baseline-requirements/requirements/#4911-reasons-for-revoking-a-subscriber-certificate>
>>>> when a publicly-trusted CA Owner has violated CAA expectations.
>>>>
>>>> Studying CAA-related incident reports disclosed to Bugzilla over the
>>>> past ~5 years, it appears there *might* be mixed interpretations of
>>>> the required revocation timelines when CAA is violated. The evaluations
>>>> below were based on a quick, non-comprehensive scan of CAA-related incident
>>>> reports disclosed to Bugzilla, where we attempted to interpret the
>>>> understood revocation timelines described in the incident reports based on
>>>> observed revocation behavior, which wasn’t always clear.
>>>>
>>>>
>>>>    -
>>>>
>>>>    SSL.com: CAA Empty set handling results in Wildcard issuance
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1932973> (certificates
>>>>    revoked within 24 hours)
>>>>    -
>>>>
>>>>    SSL.com: Failure to process CAA records from one SubCA
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1938236>
>>>>    (certificates revoked within 24 hours)
>>>>    -
>>>>
>>>>    DigiCert: Unclear Disclosure of CAA Issuer Domain Names
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1914911> (certificates
>>>>    revoked within 5 days)
>>>>    -
>>>>
>>>>    GoDaddy: CAA checks passed when records contained incorrect
>>>>    variants of godaddy.com or starfieldtech.com
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1904749>] (certificates
>>>>    revoked within 5 days)
>>>>    -
>>>>
>>>>    GoDaddy: CAA checks did not properly handle issuewild tag allowing
>>>>    FQDN SANs to be added to wildcard certs
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1904748>
>>>>    (certificates revoked within 5 days)
>>>>    -
>>>>
>>>>    Google Trust Services: SXG certificates issued without correctly
>>>>    checking CAA restrictions
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1902670>
>>>>    (certificates revoked within 24 hours)
>>>>    -
>>>>
>>>>    Apple: TLS certificates issued outside the TTL of the CAA record
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1841534>
>>>>    (certificates revoked within 5 days)
>>>>    -
>>>>
>>>>    GlobalSign: Certificate issued to FQDN with malformed CAA
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1759854>
>>>>    (certificates revoked within 24 hours)
>>>>    -
>>>>
>>>>    Amazon Trust Services: Missing CAA Check For Test Website
>>>>    Certificates <https://bugzilla.mozilla.org/show_bug.cgi?id=1746945>
>>>>    (certificates revoked within 24 hours)
>>>>    -
>>>>
>>>>    Let's Encrypt: CAA Rechecking bug
>>>>    <https://bugzilla.mozilla.org/show_bug.cgi?id=1619047>
>>>>    (certificates revoked within 5 days)
>>>>
>>>>
>>>> From our view, it seems a 24-hour revocation window is more appropriate
>>>> than a 5-day window. If CAA is to be interpreted as a security function
>>>> explicitly enabled by a domain owner that is intended to prevent
>>>> certificate issuance by unauthorized CAs, it feels odd to treat this
>>>> differently than TLS BR 4.9.1.1 (2), which states “The Subscriber
>>>> notifies the CA that the original certificate request was not authorized
>>>> and does not retroactively grant authorization (CRLReason #9,
>>>> privilegeWithdrawn);”. We recognize that a request not being
>>>> authorized and issuance not being authorized are indeed distinct, but
>>>> from our view they appear to communicate the same conclusion in that from
>>>> the subscriber’s perspective issuance should not have taken place.
>>>>
>>>> We were hoping to collect opinions from this group to ultimately inform
>>>> next steps, which might include clarifying expectations within the
>>>> CA/Browser Forum TLS BRs.
>>>>
>>>> As always, additional discussion is welcome and we’re open to changing
>>>> our perspective.
>>>>
>>>> Thanks for your consideration in participating in this discussion!
>>>>
>>>> - Ryan, on behalf of the Chrome Root Program
>>>>
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