All,
This email commences a six-week public discussion of SSL.com’s request to include the following certificates as publicly trusted root certificates in one or more CCADB Root Store Member’s program. This discussion period is scheduled to close on May 2, 2023.
The purpose of this public discussion process is to promote openness and transparency. However, each Root Store makes its inclusion decisions independently, on its own timelines, and based on its own inclusion criteria. Successful completion of this public discussion process does not guarantee any favorable action by any root store.
Anyone with concerns or questions is urged to raise them on this CCADB Public list by replying directly in this discussion thread. Likewise, a representative of the applicant must promptly respond directly in the discussion thread to all questions that are posted.
CCADB Case Numbers: 00001049 and 00001132
Organization Background Information (listed in CCADB):
CA Owner Name: SSL.com
Website: https://www.ssl.com/
Address: 3100 Richmond Ave., Suite 405, Houston, Texas, 77098, United States of America
Problem Reporting Mechanisms: sup...@ssl.com, https://www.ssl.com/revoke/
Organization Type: Public Corporation
Repository URL: https://www.ssl.com/repository/
Certificates Requesting Inclusion:
SSL.com TLS RSA Root CA 2022 (included in case 00001049):
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Client Authentication 1.3.6.1.5.5.7.3.2
Test websites:
SSL.com TLS ECC Root CA 2022 (included in case 00001049):
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Client Authentication 1.3.6.1.5.5.7.3.2
Test websites:
SSL.com Client ECC Root CA 2022 (included in case 00001132):
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4
Client Authentication 1.3.6.1.5.5.7.3.2
Test websites: N/A
SSL.com Client RSA Root CA 2022 (included in case 00001132):
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4
Client Authentication 1.3.6.1.5.5.7.3.2
Test websites: N/A
Existing Publicly Trusted Root CAs from SSL.com:
SSL.com EV Root Certification Authority ECC:
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Code Signing 1.3.6.1.5.5.7.3.3
Time Stamping 1.3.6.1.5.5.7.3.8
Certificate corpus: here (login required)
Included in: Apple, Chrome, Microsoft, and Mozilla
SSL.com EV Root Certification Authority RSA R2:
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Code Signing 1.3.6.1.5.5.7.3.3
Time Stamping 1.3.6.1.5.5.7.3.8
Certificate corpus: here (login required)
Included in: Apple, Chrome, Microsoft, and Mozilla
SSL.com Root Certification Authority ECC:
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4
Client Authentication 1.3.6.1.5.5.7.3.2
Code Signing 1.3.6.1.5.5.7.3.3
Document Signing AATL 1.2.840.113583.1.1.5
Document Signing MS 1.3.6.1.4.1.311.10.3.12
Certificate corpus: here (login required)
Included in: Apple, Chrome, Microsoft, and Mozilla
SSL.com Root Certification Authority RSA:
Certificate download links: (CA Repository, crt.sh)
Use cases served/EKUs:
Server Authentication (TLS) 1.3.6.1.5.5.7.3.1
Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4
Client Authentication 1.3.6.1.5.5.7.3.2
Code Signing 1.3.6.1.5.5.7.3.3
Document Signing AATL 1.2.840.113583.1.1.5
Document Signing MS 1.3.6.1.4.1.311.10.3.12
Time Stamping 1.3.6.1.5.5.7.3.8
Certificate corpus: here (login required)
Included in: Apple, Chrome, Microsoft, and Mozilla
Relevant Policy and Practices Documentation:
The following apply to all four (4) applicant root CAs:
Most Recent Self-Assessment:
The following apply to all four (4) applicant root CAs:
https://bugzilla.mozilla.org/attachment.cgi?id=9302401 (completed 11/7/2022)
Audit Statements:
Auditor: BDO International Limited (enrolled through WebTrust)
Audit Criteria: WebTrust
Date of Audit Issuance: 9/27/2022
For Period Ending: 6/30/2022
Audit Statement(s):
Standard Audit (covers all four (4) applicant root CAs)
BR (SSL) Audit (covers all four (4) applicant root CAs)
EV SSL Audit (only covers “SSL.com TLS RSA Root CA 2022” and “SSL.com TLS ECC Root CA 2022”)
Incident Summary (Bugzilla incidents from previous 24 months):
1790693: SSL.com: Issuance of 1 EV TLS certificate using a Registration/Incorporation Agency not included in our approved public list.
1800753: SSL.com: Delayed revocation of certificate with weak key
1719916: SSL.com: Issuance of an EV TLS certificate with incorrect O Field Value
1722089: SSL.com: Issuance of 3 EV TLS certificates without 2-person validation of the organization information
1724520: SSL.com: Incorrect Domain Validation for 1 TLS certificate with FQDN having "www." string within domain labels
1750631: SSL.com: Issuance of TLS certificates with validation methods prohibited by SC-45
1752636: SSL.com: Delayed revocation of 53 certificates affected by bug #1750631
Thank you,
Chris, on behalf of the CCADB Steering Committee
In response to https://groups.google.com/a/ccadb.org/g/public/c/mTUkK-gkHPE/m/WBaf7QUnAwAJ, starting from the Matthias’ last statement we would like to point to our actions as explained in [1], [2] and [3], which demonstrate SSL.com’s ability to monitor, analyze and take informed decisions, addressing particular cases in accordance with the BRs.
More specifically, our immediate actions demonstrate:
i) active monitoring of industry channels such as m.d.s.p., which allowed capturing a case which was not reported via the required channels, as published in our CP/CPS section 4.9.3 per provisions of BRs section 4.9.3;
ii) ability to respond swiftly with expedited deployment and testing of technical control updates (pre-issuance linting), effectively blocking any similar issuances;
iii) provident care to retrospectively test against the entire corpus of certificates, confirming no other occurrences exist;
iv) due diligence by promptly analyzing the technical and compliance aspects of the issue at hand, considering the relevant literature and the applicable requirements, thus leading to informed decisions instead of acting hastily;
v) eagerness to test our processes and identify possible improvements by handling the issue as a real-world case, acting in communication with the subscriber and reporter (in this case, the same person).
In our opinion, completing the above-mentioned actions (analysis, decision, notification, revocation, retrospection and mitigation) within 26 hours, is not a sign of “SSL.com's lack of urgency regarding detecting, handling, and responding” as stated in Matthias opening statement.
It is worth explaining the rationale of our actions, and more specifically why we didn’t make an earlier revocation decision. Context played a decisive role here. If we had received a Certificate Problem Report (CPR) per section 4.9.5 of the BRs, we would be forced to follow the exact deadlines specified in the CPR procedure (confirmation, revocation decision and execution within 24 hours of receipt of the CPR). We would have a significantly different approach (lower level of analysis depth, lower priority in updating preventive controls, etc.). Since this case was reported in a public mailing list, we considered it better to do a more in-depth analysis as due diligence and use this time to prioritize other equally important actions (preventive controls, retrospection).
Overall, we would like to state that this is not a case of a CA trying to escape its obligations. With [3] we made clear that, in our opinion, and in accordance with the expectations of the industry, a CA may not arbitrarily extend the period of investigation and use it as an excuse to delay revocation. We have also been completely transparent and tried to detail the rationale of our actions. As stated in [2], if the root store owners considered this a violation or found any value in filing an incident report, we would do so. However, no such request was made (for the more than two months after our December response, which further explained our rationale); on the contrary, [4] is a clear indication that our actions were considered reasonable and compliant.
As a publicly-trusted CA, we have handled numerous cases of CPRs reporting vulnerable or other forms of compromised keys and we have followed the requirements to the letter. Our annual audits confirm our compliance with these requirements.
However, we are using this case as a learning opportunity. Handling it as a real-world report, rather than as a security researcher’s exercise, allowed us to test our processes and draw useful conclusions which will improve our understanding and the maturity of our processes going forward. For example, this allowed us to do further research on weak keys, which is shortly presented in [6] and which will be used in delivering Ballot SC-59.
[1]
https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/TlhjCJm610I/m/LmlR3tJCBAAJ
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c2
[3]
https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c6
[4]
https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c7
[5]
https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c8
[6] https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c11
All,
I have just completed a CP/CPS review of SSL.com's CP/CPS v. 1.16 and attached it to Bugzilla Bug #1799533 (https://bugzilla.mozilla.org/show_bug.cgi?id=1799533). See https://bugzilla.mozilla.org/attachment.cgi?id=9327554 (Excel Spreadsheet).
I would like SSL.com to read through my comments and respond to them in Bug # 1799533.
Thanks,
Ben
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All,
This is a reminder that the public discussion period on the inclusion application of SSL.com will close next Tuesday, on May 2, 2023.
Thank you,
Chris, on behalf of the CCADB Steering Committee
To view this discussion on the web visit https://groups.google.com/a/ccadb.org/d/msgid/public/6a8dca06-087e-4818-b41a-5e5212271ffcn%40ccadb.org.
All,
On March 21, 2023, we began a six-week, public discussion [1] on the request from SSL.com for inclusion of its root certificate(s):
The public discussion period ended on May 2, 2023.
Summary of Discussion
Discussion Item #1: Concerns were raised about SSL.com’s lack of urgency in detecting, handling, and responding to weak public keys and their ability to comply with the BRs in areas without specific guidelines, especially when it comes to security and revocation timelines.
SSL.com Response to Discussion Item #1: SSL.com believes their actions in [2], [3] and [4] demonstrate their ability to monitor, analyze, and make informed decisions in accordance with the BRs. It was pointed out that the actions in [3] demonstrate a commitment to addressing concerns, and the context in which the issue was reported influenced the decision to perform a more in-depth analysis. It was also mentioned that this incident is being used as a learning opportunity to test and improve processes, and the experience has informed their research and contributions to Ballot SC-59.
Discussion Item #1 Continued: It was stressed that CAs must respond to certificate issues promptly per Section 4.9.1.1, regardless of how they discover the problem. An interpretation of the timeline in Incident Report 1800753 [5] was provided, and it was suggested that SSL.com should have known of a certificate’s vulnerability and revoked it within 24 hours.
Discussion Item #2: Ben Wilson commented on the SSL.com CP/CPS v. 1.16. [6]
SSL.com Response to Discussion Item #2: SSL.com is updating the CP/CPS to version 1.17 with expected publication on or before May 15, 2023. [7]
==========================
We thank community members for their review and consideration during this period. Root Store Programs will make final inclusion decisions independently, on their own timelines, and based on each Root Store Member’s inclusion criteria. Further discussion may take place in the independently managed Root Store community forums (i.e., MDSP).
[1] https://groups.google.com/a/ccadb.org/g/public/c/mTUkK-gkHPE/m/bBl1fCN5AAAJ
[2] https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/TlhjCJm610I/m/LmlR3tJCBAAJ
[3] https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c2
[4] https://bugzilla.mozilla.org/show_bug.cgi?id=1800753#c6
[5] https://bugzilla.mozilla.org/show_bug.cgi?id=1800753
[6] https://bugzilla.mozilla.org/show_bug.cgi?id=1799533#c6
[7] https://bugzilla.mozilla.org/show_bug.cgi?id=1799533#c11
Thank you,To view this discussion on the web visit https://groups.google.com/a/ccadb.org/d/msgid/public/CA%2B1gtaaoGgHOrPNwp7R-Uj9%3DC_vDiiq9f9NhbuqBjOGQ8JJi3g%40mail.gmail.com.