Hi Amir,

>I also wanted to ask in general, why does WHOIS based validation not fall 
>under the same rules as a delegated third party for domain validation? 

In my personal opinion (but perhaps others have a different opinion on this), 
because there needs to be a source of truth, for the same reason we do allow 
DNS, and by that any, validation. 

With any DCV method, a third party is always used. And by that I do not mean 
using 8.8.8.8 or 1.1.1.1 for DNS queries, that obviously is a not-allowed 
practice. However, I’d claim that the *.root-servers.net are still a third 
party. We just see it as the single source of truth for DNS and walk the tree 
from there. (And that list of authorized servers, is also maintained by IANA: 
https://www.iana.org/domains/root/servers 
<https://www.iana.org/domains/root/servers>). 

Regards,

Martijn 

From: Servercert-wg <[email protected]> on behalf of Amir 
Omidi via Servercert-wg <[email protected]>
Date: Tuesday, 24 September 2024 at 00:07
To: Aaron Gable <[email protected]>, CA/B Forum Server Certificate WG 
Public Discussion List <[email protected]>
Subject: Re: [Servercert-wg] Transitive Trust and DCV (was Re: Ballot SC-080 
V1) 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe. 


This is a really good point Aaron. Thank you. 



I also wanted to ask in general, why does WHOIS based validation not fall under 
the same rules as a delegated third party for domain validation? 



On Mon, Sep 23, 2024 at 18:03 Aaron Gable via Servercert-wg 
<[email protected] <_blank>> wrote: 

While I agree with Andrew's points about how the ACME validation methods can be 
MITM'd, I disagree with the conclusion that this makes them equivalent to 
WHOIS-based methods. 


When an adversary MITMs one of the ACME validation methods, they are taking 
control of the domain in question. By manipulating the structure of the 
internet (usually via BGP hijacking) they are exerting control over the content 
seen at that domain name by a whole section of the internet -- a section that 
just so happens to include the CA performing validation. However briefly, they 
did in fact demonstrate control over that domain. 



When an adversary MITMs a CA's WHOIS query, the domain being validated remains 
untouched. The adversary has not shown any control over the domain in question, 
only over the CA, or over a largely-unrelated third party. 



This is the fundamental weakness of all secret-token based methods. All that is 
required is that the adversary take control of something other than the domain 
in question so that they can get the secret delivered to them. If I had my 
personal druthers, I would limit domain control validation to only methods 
where the token being public knowledge is not considered a weakness of the 
validation protocol. 




Aaron 



On Fri, Sep 20, 2024 at 10:47 AM Dimitris Zacharopoulos (HARICA) via 
Servercert-wg <[email protected] <_blank>> wrote: 

Hi Mike, 
On 19/9/2024 5:22 μ.μ., Mike Shaver via Servercert-wg wrote: 

Hi Dimitris, 



I've been thinking about your email all night, and I want to figure out where 
our reasoning about the integrity of DCV via WHOIS-1932 or HTTP-nonce 
(3.2.2.5.1) diverge. I was quite surprised by your statements about the 
properties of internet security, the responsibility of TLS and SCWG, and the 
limitations that should be accepted in performing DCV. I'm hoping that your new 
responsibilities as Chair (congratulations!) will still leave you a bit of time 
to point out where my reasoning doesn't connect. :) 



Thank you for that :) New officers will start their duties on 2024-12-01 but I 
believe Member's contributions to the Forum are a lot more important when we're 
having these discussions, working on ballots and continuously improving the 
standards! Officers mainly have to do the "administrative" work and make sure 
the WG Charter and Bylaws are followed. 





Because I'm not sure where we diverge, I'm going to walk through my 
understanding of the principles underlying the DCV methods used historically by 
CA/BF (and CAs in the dark days of private deals with individual browsers), and 
the direction towards which the SCWG and root programs seem to be headed in 
terms of those principles. Please, *please* do not take this as me implying 
that you don't know these things: I'm not trying to lecture, but to be as 
explicit as reasonable in explaining my thinking, so that it's easiest for 
yourself or others to help me correct error in it. I would be quite grateful 
for such generosity, honestly! I also apologize in advance for the length of 
this message. I lack the wisdom to make it smaller, perhaps. 



(Some of this is entangled with "what is this even for?" sorts of discussion 
about who the web PKI should ultimately benefit, but I've tried to keep that 
separate.) 



On Wed, Sep 18, 2024 at 12:18 PM Dimitris Zacharopoulos (HARICA) 
<[email protected] <_blank>> wrote: 

We don't need Domain Name Registrars to go through WebTrust or ETSI audits 
suitable for Trust Service Providers. These Registrars are the source of truth 
for the DNS on which all Internet connections, and the WebPKI relies on. It's 
so fundamental to the ecosystem that IMO it doesn't make sense to ask ourselves 
how this Forum can make them better. Other authorities should be working on 
that. 



A recurring theme throughout web PKI operations has been that a participant in 
the ecosystem thinks that they are doing a good job, and perhaps indeed are 
doing a good job of some kind, but are not providing the guarantees or 
protections that others are assuming are in place. I don't mean "good job" in 
the sense of competence or ethics, but rather "meeting the requirements through 
actions". The farther that the participant is from the core of the web PKI 
ecosystem, which is to say the less likely they are to evaluate all their 
actions by the effects of those actions on the trustworthiness of web 
certificates and server authentication. This means, IMO, that this group and 
other stewards of the PKI should be very conservative, and very explicit, when 
depending on another participant of the ecosystem to maintain certain 
properties. Otherwise, those dependency-bearing organizations may not even know 
what is being expected of them. 



I am not suggesting that CA/BF in any way place requirements on what an 
organization must do in order to be a domain registrar, and reporter of that 
registry. As you say, that is beyond both the scope and the expertise of this 
group, and this group has plenty to keep it busy! I am, rather, suggesting that 
SCWG should establish criteria against which it will determine if a registrar's 
publication of domain information should be considered to be reliable enough to 
accomplish DCV. Similarly, the group does not put any requirements forcing 
public DNS servers to strictly check DNSSEC, but if a CA is going to use a DNS 
server for checking CAA records or doing 3.2.2.4.7 "DNS Change" validation, 
then that's only acceptable if the DNS server enforces DNSSEC in the presence 
of a validation chain. (I think that might only be in Bugzilla and not yet 
captured in the BRs, but it's well-enough understood that failure to adhere to 
it has required reissuance.) 




I see your point. In general, as you say, it is difficult for a group like the 
CA/B Forum to enforce rules and expectations placed upon another industry group 
(Domain Name Registrars/TLD Operators) if those other industry groups do not 
participate or don't even have knowledge about those expectations. I would be 
very concerned if the SCWG or the Forum at large, would create a set of 
"expectations from a Registrar/TLD Operator to be considered good-enough for 
the WebPKI to rely upon". I think this group would be heavily criticized for 
doing that.

If we believe this area is so security-critical for the WebPKI, the best think 
we could do is to have members of this Forum engage with IANA or other 
ccTLD-coordinating venues to promote ideas for improved security, external 
monitoring and transparency. It feels similar to what Members of this Forum 
have done in the past when we bring up ideas for improving the security of our 
ecosystem, and bring those ideas to IETF (LAMPS WG or other similar venues) to 
standardize.

I'm not opposed to adding requirements that prohibit the use of external 
information in egregious failure cases, but it's not easy to find the right 
language in a standard for this.





If a ".cookoo" TLD operator is not functioning properly, then the entire TLD is 
in jeopardy and every Domain owner under that TLD is at risk. Certificates are 
the least of people's problems when relying parties connect to websites 
operated under that unsafe TLD operator. 



As above, this depends very much on exactly what form "not functioning 
properly" takes. If their systems are broken such that it's impossible to make 
changes to registrations, or to look up registrations, I think we would all 
agree that the TLD operator is not functioning properly, but that would not 
have as much risk to the integrity of the web PKI as those systems being broken 
such that *anyone* can change any TLD. 



For CAs to rely on email address information from registrars for issuance of 
certificates, I think it's only appropriate that they ensure that the 
information is "fit for purpose" and that it's managed (and accessed) in a way 
consistent with the level of trust placed in it. 



This means making sure that the integrity of the response is maintained, which 
is a role that WHOIS-3912 simply cannot perform. 


No, the SCWG and TLS is not here to solve the unencrypted nature of the DNS 
protocol. IETF and DNSSEC is. There is a great number of Domain Names in the 
DNS without DNSSEC, and there is still heavy reliance on the unencrypted DNS 
protocol in almost EVERY Domain Validation under 3.2.2.4. 


DNS being unencrypted is not a problem, and indeed even DNSSEC doesn't encrypt 
traffic. DNS results being *unauthenticated* is a problem for clients who wish 
to be certain that they have been given an authorized address in response to 
their lookup, but even with DNSSEC that leaves the issue of ensuring that the 
unauthenticated IP layer reached the "real" home of that address (thus DANE). 



Even the Agreed-upon change to website method, 3.2.2.4.18, relies on 
"Authorized Ports that are offered via non-encrypted channels (ports 80, 25, 
22). 


Again, encryption during validation is not necessary for there to be a reliable 
chain of trust from the browser to the site certificate, via CA-operated root 
certificates. We need authentication, but only authentication, of every step of 
the delegation of trust. 



I would go as far as to say that even the ACME methods connecting to https URLs 
are untrusted, because the endpoints are not protected by publicly trusted 
certificates and anyone could launch a MiTM attack. 



This is a part that really got stuck in my head. Are you saying that ALPN-1 is 
vulnerable to a MITM attack during validation? That would be a pretty shocking 
situation, in my opinion! 



How would the attacker get access to the key material needed to complete the 
challenge? It never leaves the subscriber machine from what I can tell. 
Similarly, the ACME account key is used in HTTP-01 to render MITM attacks 
ineffective. 



This is how the trust in that connection is bootstrapped based on the trust in 
the connection between subscriber and CA when the certificate is requested. 
Presumably publicly-trusted certificates are used when the subscriber connects 
to the CA's server to make that request and obtain the account key! 



This transitivity of trust goes to the issue with WHOIS. Even if the registrar 
is maximally diligent in their key ceremonies and internal processes and 
generating certificates correctly, WHOIS-3912 puts a *maximum* trustworthiness 
on the entire operation, which is that of unauthenticated TCP. In my opinion, 
that is not appropriate for web PKI, and is a relic of a time before this 
community took technical registration-time attacks as seriously as we do now. 




I consider Andrew's response <_blank> a lot clearer than mine. I believe it 
answers your questions and how to MiTM the ACME TLS-ALPN-01 challenge.






In order for the SCWG measures to be proportionate, we should not blame the 
entire WHOIS protocol but work on additional controls to minimize the risk of 
CAs using those problematic WHOIS libraries. 
Could you describe how a non-problematic WHOIS-3912 library could provide 
assurance of the validity of the data returned, equivalent to the integrity of 
the results from HTTP-01/DNS-01/ALPN-01? 




Assuming no MiTM, it's no different than any of those methods. The CA "trusts" 
that the information is coming from an authoritative source or from a source 
that demonstrated control of the Authorization Domain Name. In the HTTP-01 
case, it retrieves a random value or request token from a designated URL that 
contains the FQDN to-be-included in the Certificate. In the WHOIS case, it 
retrieves the email address of a tech or admin contact associated with the 
registration of that Base Domain Name.

The .mobi issue, in my understanding, is that some CAs were (still are?) using 
WHOIS libraries that were not looking for the currently authoritative Registrar 
of that TLD. If the SCWG could identify those insecure libraries, or if 
criteria were added to use libraries that check for the most recent 
authoritative source for each Base Domain Name Registrar, it would be a good 
emergency mitigation.

We had a similar discussion when discussing the linting tools. At some point we 
need to add rules for continuous updates, taking into account proper testing 
and change management procedures.



Instead, we could focus on requiring immediate/emergency measures for CAs to 
use the WHOIS protocol securely 





This is definitely one place that our reasoning diverges: I don't see a way to 
use WHOIS-3912 securely, where by "securely" I mean "in such a way as to not 
weaken the DCV guarantees that the web PKI wishes to make". 





I disagree. We are trying to move from "http" to a "trustworthy https" (note: 
"trustworthy https" in the sense that it doesn't use untrusted certificates). 
At some point, CAs need to rely on unencrypted communication to achieve that. 




Why do CAs need to rely on unauthenticated communication to achieve that? If we 
were establishing the very first root, someone would have to carry the key 
physically to the browser developer as a form of IRL authentication, but we 
have sufficient systems in place now to inductively create a completely 
authenticated chain of validation if we should want to. 



Where is that chain impossible to authenticate, in your opinion? 






Andrew's answer covers this very clearly IMO. This is just how it works. There 
is no single source of truth or "one key to rule them all" that everyone 
trusts. The closest we have is the DNS.




I'm confused by this statement. Is this a plea to the CAs to stop using what 
you think is an insecure method? 



Yes, it is exactly that. I don't know how anyone can seriously claim that 
WHOIS-3912 is a secure method, regardless of how high quality the data on the 
other side is. 




Then the second sentence of my snipped quoted statement applies:

"Everyone is entitled to an opinion but that's why we are having these 
discussions publicly so that the SCWG members can find "substantial consensus" 
as mandated in the Bylaws. I'm sure some CAs are already working, or have 
already stopped using WHOIS, proactively, until this discussion comes to an 
end."



Domain Registries for validation of domain contacts: domain registry 
information should, IMO, only be used at *all*, independent of protocol, if the 
SCWG can be confident that IANA or another trusted body will be able to ensure 
that all those registries, for all domains present and future, will meet the 
SCWG's requirements for reliability. 


This is like saying that the Registrars, the main stewards assigned to run the 
DNS which is fundamental for how the Internet works and practically the World 
Wide Web, need to meet the SCWG requirements for reliability. 



As above, domain registrars do not need to meet any SCWG requirements. CAs need 
to meet the SCWG requirements, and I think that those requirements should 
include minimum properties that must hold of a registrar's data management 
practices, and the means of accessing it, if such data is to be used as 
authoritative proof of domain control. 



An example: do registrars inform registrants that anyone who can receive email 
at the listed contact address can be issued a certificate for their domain? I 
think that the significance of that address as used for DCV is not 
well-understood by most registrants, and that many will send that email to 
ticket/CS lists composed of people who are *not* authorized to make changes to 
DNS, and are not assumed to have the same authority for requesting 
certificates. Similarly, I don't think that registrants understand that someone 
popping a domain-privacy provider not only gets their email and contact 
information, but could plausibly also silently have certificates issued against 
their domain. 



If these participants in the ecosystem (registrar and registrants) don't regard 
the email contact field as having such immense security significance, then it 
is unlikely that they will manage it with appropriate care. Given that, as you 
correctly point out, the SCWG is in no position to put requirements on 
registrars or registrants, all that we can do is say that CAs must not use 
registrar data unless it is managed to an appropriate standard, and accessed in 
an appropriate way. That is *well* within the mandate of the SCWG, and 
consistent with all of its other activities in defining validation standards. 




This is a very tough sell because there is no stop to this line of arguments. 
Should CAs also monitor the behavior of Internet Service Providers responsible 
of the Internet connectivity? Should they monitor Telecommunication Providers 
for how they run the SMS GSM networks used by CAs to contact Applicants? Should 
they monitor the Postal Services when sending letters to Applicants?

The publicly-trusted ecosystem (WebPKI in the SCWG) needs to rely on some 
fundamental services offered by entities outside the scope of the CA/Browser 
Forum, that are governed by their own policies and practices. The CABF cannot 
police or directly intervene with these fundamental services at a global level.





I believe the WHOIS deprecation could follow a similar pattern but for sure the 
SCWG should urgently focus on requiring CAs to use WHOIS libraries that query 
the proper Registrar endpoints, IF they are using the WHOIS method to query 
Domain Contact information 




If CAs are going to continue to use WHOIS-3912, I think that the SCWG should 
require that the traffic be carried over an authenticated TLS channel, or that 
the response be signed. Anything less doesn't address the fundamental 
insecurity of the *access protocol*, whatever the truth of the data returned in 
the request. Do you feel that unauthenticated requests over the public internet 
really have a place in DCV? 






Based on Andrew's and my answers, I hope you can see that this point just 
doesn't apply.





Saying that the internet is fundamentally insecure is like saying that 
electricity is fundamentally insecure, to me. The base protocols of the 
internet, like IP, don't provide sufficient security properties given the 
importance of the modern web. But just as TCP provides in-order delivery over 
un-ordered IP, and TLS provides privacy and integrity over TCP (which features 
neither of those, save a trivial attempt at integrity aimed at signalling 
errors and not malicious interception), the web PKI can provide authentication 
of domain ownership and connection validity by layering appropriate protocols 
(computer and human) atop the less-capable lower layers. That to me is the 
essence of the mandate of the SCWG. We are to TLS what ICANN is to DNS: ICANN 
doesn't say that you can't return arbitrary nonsense in a DNS response from 
your server on a private network, but it *does* say that if you want to operate 
a DNS server on behalf of a gTLD, you need to meet certain requirements or 
ICANN simply won't point traffic at you. We should "stop pointing traffic" at 
certificates that were validated using WHOIS-3912 DCV, and I wish I'd pushed to 
do so multiple decades ago. 






Apologies for oversimplifying, but I just want to clarify what I meant. The 
Internet was built on some principles. These principles included anonymity and 
clear-text communication. Encryption and authentication came later, but they 
were built on top of the anonymous/clear-text layers.

What does "secure the Internet" mean? There are various answers to that 
statement but one answer is "the assurance that communication between two 
points (point-to-point) is authenticated and encrypted". For this you need 
cryptography but you need to solve the key distribution problem. One solution 
is the WebPKI. There are other solutions (DANE, VPN, etc).

In order to validate a Domain Name and verify a binding between a key and a 
name, a CA must use some parts of the unauthenticated/unencrypted Internet in 
order to get assurance that it is interacting/communicating/contacting the 
proper and authorized recipient. I don't think there is a way around that.

Dimitris. 

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