Symantec Update on SubCA Proposal

[Steve Medin]

*Progress Update on SubCA RFP, Partner Selection, and Execution*



Since June 1, Symantec has worked in earnest to operationalize the SubCA proposal outlined by Google and Mozilla and discussed in community forums. The core of this proposal is to transfer the authentication and issuance of certificates to a set of new SubCAs that are operated by "Managed CAs", with the eventual end state being a move from the existing Symantec PKI to a modernized platform. We are providing this update to share our initial findings of our efforts to implement the SubCA proposal, and as previously posted, propose aggressive but achievable dates for certain aspects of the SubCA proposal.



Last month, we released a Request for Proposal (RFP) that covered all aspects of the SubCA proposal, including key management, technical integration, staffing, training, compliance, support, and the end-to-end coordination of operations. This RFP was sent to the CAs that we felt best met the browser requirements and had the potential to successfully fulfill the scope and volume of our CA authentication and issuance activities.



After receiving RFP responses, we met with the prospective Managed CAs to discuss and refine their proposed approach, clarify intent and answer questions impacting their proposals, which addressed their approach to and schedule for integration, staffing, compliance, support, and other operational aspects. Over the last two weeks, we have continued to receive detailed responses from RFP respondents and hold meetings with the prospective Managed CAs to review their proposals in order to select the final Managed CA partner(s) that will be able to best execute on the plan proposed by Google and Mozilla. We appreciate the CAs who have replied and recognize that drafting the proposals required a tremendous amount of time and effort as part of this accelerated process.



We continue to work through implementation details with our prospective Managed CA partners, to understand the depth of analysis that has gone into their development schedules and staffing plans, and to assess the feasibility of those plans. We expect to complete the selection process within the next 2 weeks. After selecting the final Managed CA partner(s), we will work aggressively towards the execution of an agreement and integration plan.



As we finalize the selection process, our development team is actively working towards the transition. Currently, we are shifting from design to implementation of a common set of APIs across platforms to simplify the integration with one or more Managed CAs.



Based on the RFP responses, internal planning, and discussions with RFP respondents to date, we are still concerned with the implementation timing. Based on both our own internal scoping and the RFP responses, we see a practical, aggressive transition being achievable between early-December and late-February, depending on the specific Managed CA(s) and the unknowns that come with an effort of this magnitude. This timeframe is based on the Managed CAs' RFP responses regarding how long it will take to integrate our existing customer portals (front-ends) with the Managed CA validation and issuance systems. The transition timeline also incorporates the effort required for the Managed CAs to build out support for scalable domain validation (both automated and manual), CAA record checking, CT logging, and certificate management functions. The primary factors we heard from potential Managed CA partners are the need to scale their operations to the certificate volumes currently supported by Symantec, the need for integration, and the time required to prepare and process key ceremonies on both ends. Some of the prospective Managed CAs have proposed supporting only a portion of our volume (some by customer segment, others by geographic focus), so we are also evaluating options that involve working with multiple Managed CAs.



*Timing Proposal Based on Key Activities*



Based on the key activities and customer dependencies associated with the transition (additional details provided at the end of this post), we believe that the following adjustments to the current SubCA proposal timelines are appropriate and necessary. These adjustments will allow us to work toward deadlines that are as close as possible to the original dates and take into account the full scope of the required implementation efforts while prioritizing moving to full authentication by the Managed CAs for new certificates.



New Certificate Issuance: We believe the dates for transition of validation and issuance to the Managed CA that are both aggressive and achievable are as follows:

- Implement the Managed CA by December 1, 2017 (changed from August 8, 2017);

- Managed CA performs domain validation for all new certificates by December 1, 2017 (changed from November 1, 2017); and

- Managed CA performs full validation for all certificates by February 1, 2018. Prior to this date, reuse of Symantec authenticated organization information would be allowable for certificates of <13 months in validity.



Replacement of Unexpired Certificates Issued Before June 1, 2016: There are two major milestones that must be achieved after implementation of the Managed CA in order to replace unexpired certificates issued before June 1, 2016 that do not naturally expire before the distrust date(s) in the SubCA proposal. Those include the full revalidation of certificate information and then the customer replacement of those certificates. This activity would need to start during the December holiday season when many organizations impose infrastructure blackout periods. As such, we believe that the only achievable timing for this transition is after the holiday season. We understand that browsers may want to technically enforce this transition and that multiple milestones may be undesirable from a coding perspective. In order to accommodate a simplified and cost efficient transition schedule (especially for organizations that currently have certificates with notBefore dates of both June 1, 2015 and June 1, 2016) and to allow impacted organizations the time, as they will likely need to replace, test and operationalize these replacement certificates in their infrastructure, we recommend consolidating Chrome's distrust dates to a single date of May 1, 2018. This would mean that Chrome's distrust of Symantec certificates issued before June 1, 2015 would change from August 31, 2017 to May 1, 2018, and that Chrome's distrust of Symantec certificates issued before June 1, 2016 would change from January 18, 2018 to May 1, 2018.



To add additional context, targeting May 1, 2018 would give organizations a 9-month planning and execution window to replace certificates that would be distrusted before their expiration date (assuming that the community comes to consensus to convert the SubCA proposal into an agreed upon plan by August 1, 2017). Given the hundreds of thousands of certificates that would be impacted, we think that May 1, 2018 is the earliest acceptable distrust date that does not introduce significant operational risk in the replacement of these certificates in enterprises' infrastructure. This 9-month window is significantly more aggressive than other extraordinary events that have involved early certificate replacement, such as the years of transition to 2048 bit and SHA-256 certificates. While we believe our proposed 9-month window is achievable with early customer outreach and careful planning, we urge the community to consider moving this distrust date out even further to February 1, 2019 in order to minimize the risk of end user disruption by ensuring that website operators have a reasonable timeframe to plan and deploy replacement certificates. This recommendation is echoed by our prospective Managed CA partners.



*Additional Details on Key Activities that Inform our Timing Proposal*



In this section, we provide more detailed information that forms the basis of our proposed timing modifications to the SubCA proposal. Based on our understanding of the SubCA proposal, the following activities require the most time to implement:



Development and Integration: Symantec has developed the architecture for and is working towards decoupling the retail, mid-market, enterprise, and partner facing systems from the internal authentication and signing systems backing our certificate offerings. We have developed and published an API to the prospective Managed CAs. We have also started the engineering work to integrate this new API into our systems. Technical integration with the Managed CA(s) involves establishing the connection between Symantec and the Managed CA(s) for all certificate lifecycle functions for retail, partner, and Enterprise RA models, supporting enrollment, all methods of domain verification, organization and extended validation vetting, re-authentication, replacement, renewal, cancelation, modification, revocation, CAA checking, CT logging, and CRL and OCSP response provisioning. Technical integration is focused on the engineering resource and implementation plans of the Managed CA(s), including cross-team engagement, gap filling (to address any material existing implementation differences), development, end-to-end testing, and production deployment. This activity is projected to be the most time consuming element of our transition execution - development and integration will take an estimated 16 weeks to go live with new SubCAs within the Managed CA's infrastructure.



Key Management: Key management under the Managed CA model includes the creation and cross signing of new roots by Symantec, integration with the Managed CAs for both primary and disaster recovery sites, the coordination of signing ceremonies by both parties, and scheduling audits for these activities. Key requirements in our planning are separating HSMs that would be used for these managed CAs both for management and scaling purposes, and not relying on the existing HSMs at our Managed CA partner(s). These requirements will enable an eventual seamless transition back to Symantec, without requiring subsequent SubCA changes by server operators, and are also a practical infrastructure necessity of several of the RFP respondents. HSM procurement typically takes 4-5 weeks from the point at which a purchase order is submitted. This includes the time for the HSM vendor to make the hardware available and to ship it to the key ceremony location. Once received, HSM initialization and key ceremony activities take on average 2 weeks including coordination with the auditors for the key ceremony of root CAs. Following this, the HSM needs to be configured and deployed in both active and disaster recovery data centers, including travel/secure transport, which will be an additional 1-2 week effort. In total, we expect the key migration to potentially take up to 12 weeks. These activities would be done in parallel with our other preparations for transitioning to the Managed CA(s).



Authentication Staffing and Re-authentication Efforts: The authentication activities for the volume of certificates that Symantec issues annually requires hundreds of people to conduct validation, review the validation work and authorize certificate issuance, supervise, conduct training, and audit this activity. These people operate out of multiple locations to provide 24/7 support to customers globally in local languages. Prospective Managed CAs we have engaged with confirmed that they will need to increase their staffing by comparable levels to handle our certificate volume. We researched the staffing options under local laws to enable Managed CAs to potentially retain our staff to handle the authentication volume required both for ongoing requests and the additional re-authentication effort required globally under the SubCA proposal. In any such arrangement, staff would be under the management and control of the Managed CA. We have proposed to our prospective Managed CA partners that they consider this redeployment of current Symantec staff to simplify the staff ramp, decrease training times (i.e., Symantec staff would operate under the Managed CA subject to their validation requirements and processes), and de-risk and accelerate the move to the Managed CA model.



We've also received feedback from some of our prospective Managed CA partners that they would like Symantec validation staff to continue to perform verification of identity under the baseline requirements. The Managed CA would complete all domain validation and they would make the final decision on certificate issuance. In this scenario, Symantec would continue to undertake a baseline requirement audit and WebTrust audit for as long as it operates that particular RA function. Permitting Symantec to perform just the organizational validation (not the domain validation) would give customers an uninterrupted experience while still meeting the stated objectives. We look forward to community feedback on this proposed change to the SubCA proposal.



Customer Support and Operations: The scope of our planning with the prospective Managed CAs also covers support and end-to-end operations, addressing practical considerations such as call and chat routing across organizations, issue/escalation management, coordinating ongoing system enhancements, and service level agreements (SLAs) for dozens of aspects related to supporting the authentication and issuance activities at our scale.



The factors above all depend on the integration efforts between the Managed CA(s) and Symantec. Customers and partners need to be considered in this effort as well.



Customer and Partner Dependencies: A related dependency with customers and partners that could delay transition is the time required after the key ceremony for entities to migrate to the new hierarchies. For example, some customers and/or partners have hard-coded particular SubCAs in their environments, have built applications that build trust chains in unique ways, and have other technical implementations that may be incompatible with and may delay individual organization's transitions to the new SubCA model. In addition, although we believe the Managed CA(s) and Symantec could be ready in December 2017, this time frame falls squarely within most organizations' blackout periods. To accommodate the need for customer transitions as well as any required reissuances of existing certificates by the Managed CA, we request that any distrust dates be delayed until May 1, 2018. During that time, we will work with customers and partners to update their certificates and will continue to improve and test the Managed CA implementation. Additionally, while Symantec and its Managed CA partner(s) will be ready to issue properly validated certificates in December, the actual deployment of these certificates by customers who are replacing unexpired certificates that were issued before June 1, 2016 will take time, as described earlier. We would also like to develop a clear process to evaluate exception requests that includes consultations with the browsers to handle corner cases of system incompatibility for situations with complex interdependencies that pose material ecosystem risks.



*Summary*



Implementing this proposal is a major effort for Symantec as well as the prospective Managed CAs, but it is an effort that we believe will minimize customer, browser user, and ecosystem disruption.



The implementation and distrust dates we have recommended here are based on our understanding of the constraints of the consensus proposal and at our potential Managed CA partners:



1. December 1, 2017

a. Initial implementation date (changed from August 8, 2017) of operational Managed CA.

b. Domain validation for all new certificates is performed by Managed CA(s) (changed from November 1, 2017).



2. February 1, 2018

a. Full validation for all certificates is performed by Managed CA(s). Prior to this date, reuse of Symantec authenticated organization information would be allowable for certificates of <13 months in validity.



3. May 1, 2018

a. Single date of distrust of certificates issued prior to 6/1/2016. (changed from August 31,2017 for certificates issued prior to 6/1/2015 and from January 18, 2018 for certificates issued prior to 6/1/2018)



We expect to conclude our final selection of a Managed CA partner(s) within the next 2 weeks. During this time, we welcome any final clarifications from Google, Mozilla and the rest of the community regarding the key activities and other assumptions we have outlined in this post to inform the final dates that we can incorporate into the contracting and implementation phase of this Managed CA plan.

[Steve Medin]

Correction: Summary item #3 should read:

3. May 1, 2018
a. Single date of distrust of certificates issued prior to 6/1/2016. (changed from August 31,2017 for certificates issued prior to 6/1/2015 and from January 18, 2018 for certificates issued prior to 6/1/2016).

> their operations to the certificate volumes currently sup ported by

> _______________________________________________
> dev-security-policy mailing list
> dev-secur...@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy

[Jakob Bohm]

Just for clarity:

(Note: Using ISO date format instead of ambiguous local date format)

How many Symantec certs issued prior to 2015-06-01 expire after
2018-06-01, and how does that mesh with the alternative date proposed
below:

Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S. https://www.wisemo.com
Transformervej 29, 2860 Søborg, Denmark. Direct +45 31 13 16 10
This public discussion message is non-binding and may contain errors.
WiseMo - Remote Service Management for PCs, Phones and Embedded

[Alex Gaynor]

Hi Steve,

Thank you for this update on Symantec's progress. I have a few follow-up
questions:

1) Did any of the RFP respondents indicate that they could provide the
Managed
CA solution in the timeframe originally proposed by Google? (August 8th)
Alternatively, is December 1st, 2017 the earliest date that any RFP
respondents can achieve?

2) What selection criteria is Symantec using in considering RFP responses?

3) On June 1st, Symantec wrote that "we are in the midst of a rigorous RFP
process"
(
https://www.symantec.com/connect/blogs/symantec-s-response-google-s-subca-proposal
).
In this mail you wrote that "Last month, we released a Request for
Proposal
(RFP)". How do you reconcile those?

4) There are currently rumors that Symantec is considering a sale of its CA
business
(https://www.reuters.com/article/us-symantec-divestiture-idUSKBN19W2WI).
Do
these timelines reflect that possibility, or should we expect requests to
amend this timeline in the event of a change of ownership?

Thank you,
Alex

[Steve Medin]

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+steve_medin=symant...@lists.mozilla.org] On Behalf Of

> Jakob Bohm via dev-security-policy
> Sent: Tuesday, July 18, 2017 4:39 PM
> To: mozilla-dev-s...@lists.mozilla.org
> Subject: Re: [EXT] Symantec Update on SubCA Proposal
>
>
> Just for clarity:
>
> (Note: Using ISO date format instead of ambiguous local date format)
>
> How many Symantec certs issued prior to 2015-06-01 expire after 2018-
> 06-01, and how does that mesh with the alternative date proposed
> below:
>
> On 18/07/2017 21:37, Steve Medin wrote:

> > Correction: Summary item #3 should read:
> >
> > 3. May 1, 2018
> > a. Single date of distrust of certificates issued prior to 6/1/2016.
> (changed from August 31,2017 for certificates issued prior to 6/1/2015 and
> from January 18, 2018 for certificates issued prior to 6/1/2016).
> >

Over 34,000 certificates were issued prior to 2015-06-01 and expire after 2018-06-01. This is in addition to almost 200,000 certificates that would also need to be replaced under the current SubCA proposal assuming a May 1, 2018 distrust date. We believe that nine months (from August 1, 2017 to May 1, 2018) is aggressive but achievable for this transition — a period minimally necessary to allow for site operators to plan and execute an orderly transition and to reduce the potential risk of widespread ecosystem disruption. Nevertheless, we urge the community to consider moving the proposed May 1, 2018 distrust date out even further to February 1, 2019 in order to minimize the risk of end user disruption by ensuring that website operators have a reasonable timeframe to plan and deploy replacement certificates.

[Jakob Bohm]

So when and why did Symantec issue 34,000 WebPKI certificates valid
longer than 3 years, that would expire after 2018-06-01 ?

Are these certificates issued before 2015-04-01 with validity periods
longer than 39 months?

Are they certificates issued under "special circumstances" ?

Are they certificates with validity periods between 36 and 39 months?

[David E. Ross]

It appears that Symantec wants to delay distrusting certificates until
all existing subscriber certificates reach their inherent expiration
dates.

--
David Ross

<http://www.rossde.com/>
President Trump now denies there are any tapes that
recorded his conversations with ex-FBI Director Comey.
Between when Trump hinted there might be such tapes
and his denial, there was sufficient time to destroy
any tapes.

[Eric Mill]

On Wed, Jul 19, 2017 at 11:31 AM, Steve Medin via dev-security-policy <
dev-secur...@lists.mozilla.org> wrote:

> > -----Original Message-----
> > From: dev-security-policy [mailto:dev-security-policy-
> > bounces+steve_medin=symant...@lists.mozilla.org] On Behalf Of

> > Jakob Bohm via dev-security-policy
> > Sent: Tuesday, July 18, 2017 4:39 PM
> > To: mozilla-dev-s...@lists.mozilla.org
> > Subject: Re: [EXT] Symantec Update on SubCA Proposal
> >
> >
> > Just for clarity:
> >
> > (Note: Using ISO date format instead of ambiguous local date format)
> >
> > How many Symantec certs issued prior to 2015-06-01 expire after 2018-
> > 06-01, and how does that mesh with the alternative date proposed
> > below:
> >
> > On 18/07/2017 21:37, Steve Medin wrote:

> > > Correction: Summary item #3 should read:
> > >
> > > 3. May 1, 2018
> > > a. Single date of distrust of certificates issued prior to
> 6/1/2016.
> > (changed from August 31,2017 for certificates issued prior to 6/1/2015
> and
> > from January 18, 2018 for certificates issued prior to 6/1/2016).
> > >
>

> Over 34,000 certificates were issued prior to 2015-06-01 and expire after
> 2018-06-01. This is in addition to almost 200,000 certificates that would
> also need to be replaced under the current SubCA proposal assuming a May 1,
> 2018 distrust date. We believe that nine months (from August 1, 2017 to May
> 1, 2018) is aggressive but achievable for this transition — a period
> minimally necessary to allow for site operators to plan and execute an
> orderly transition and to reduce the potential risk of widespread ecosystem
> disruption. Nevertheless, we urge the community to consider moving the

> proposed May 1, 2018 distrust date out even further to February 1, 2019 in

> order to minimize the risk of end user disruption by ensuring that website
> operators have a reasonable timeframe to plan and deploy replacement
> certificates.
>

That's pretty close to saying that nothing should happen, since almost all
the certificates will have expired by then. That certainly is the least
disruptive, but it seems contrary to the intent of the proposal.

-- Eric

> _______________________________________________
> dev-security-policy mailing list
> dev-secur...@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
>

--
konklone.com | @konklone <https://twitter.com/konklone>

[Steve Medin]

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+steve_medin=symant...@lists.mozilla.org] On Behalf Of
> Jakob Bohm via dev-security-policy
> Sent: Wednesday, July 19, 2017 12:22 PM
> To: mozilla-dev-s...@lists.mozilla.org
> Subject: Re: [EXT] Symantec Update on SubCA Proposal
>

> On 19/07/2017 17:31, Steve Medin wrote:

> So when and why did Symantec issue 34,000 WebPKI certificates valid
> longer than 3 years, that would expire after 2018-06-01 ?
>
> Are these certificates issued before 2015-04-01 with validity periods longer
> than 39 months?
>
> Are they certificates issued under "special circumstances" ?
>
> Are they certificates with validity periods between 36 and 39 months?
>
>

The vast majority of these certificates were issued prior to April 1, 2015 and were subject to the 60 month rule that was in effect at the time of issuance. This population also includes several thousand that are for <39 month validity.

[Steve Medin]

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+steve_medin=symant...@lists.mozilla.org] On Behalf Of
> David E. Ross via dev-security-policy
> Sent: Wednesday, July 19, 2017 12:48 PM
> To: mozilla-dev-s...@lists.mozilla.org
> Subject: Re: [EXT] Symantec Update on SubCA Proposal
>

> On 7/19/2017 8:31 AM, Steve Medin wrote:

> May 1, 2018) is aggressive but achievable for this transition - a period

> minimally necessary to allow for site operators to plan and execute an
> orderly transition and to reduce the potential risk of widespread ecosystem
> disruption. Nevertheless, we urge the community to consider moving the
> proposed May 1, 2018 distrust date out even further to February 1, 2019
> in order to minimize the risk of end user disruption by ensuring that website
> operators have a reasonable timeframe to plan and deploy replacement
> certificates.
> >
>

> It appears that Symantec wants to delay distrusting certificates until all
> existing subscriber certificates reach their inherent expiration dates.
>

Our proposed distrust date (May 1, 2018) is based on an aggressive but achievable period of time to allow impacted organizations the time needed to replace, test and operationalize replacement certificates in their infrastructure. More than 234,000 certificates are required to be replaced before their expiration dates assuming a distrust date of May 1, 2018. In fact, we urge the community to consider moving this distrust date out even further to February 1, 2019 in order to minimize the risk of end user disruption by ensuring that website operators have a reasonable timeframe to plan and deploy replacement certificates. This recommendation is echoed by our prospective Managed CA partners.

[Steve Medin]

We believe our proposed dates reflect an aggressive but achievable period of time to implement the SubCA proposal and allow impacted organizations the time needed to replace, test and operationalize replacement certificates in their infrastructure to mitigate interoperability and compatibility risk associated with this premature replacement of certificates, which is consistent with the intent of the SubCA proposal. Our proposed dates are informed by the RFP responses and follow-up discussions we have had with our prospective Managed CA partners.





From: Eric Mill [mailto:er...@konklone.com]
Sent: Wednesday, July 19, 2017 3:43 PM
To: Steve Medin <Steve...@symantec.com>
Cc: mozilla-dev-s...@lists.mozilla.org
Subject: Re: [EXT] Symantec Update on SubCA Proposal

On Wed, Jul 19, 2017 at 11:31 AM, Steve Medin via dev-security-policy <dev-secur...@lists.mozilla.org<mailto:dev-secur...@lists.mozilla.org>> wrote:

> -----Original Message-----

> From: dev-security-policy [mailto:dev-security-policy-<mailto:dev-security-policy->
> bounces+steve_medin=symant...@lists.mozilla.org<mailto:symant...@lists.mozilla.org>] On Behalf Of
> Jakob Bohm via dev-security-policy
> Sent: Tuesday, July 18, 2017 4:39 PM
> To: mozilla-dev-s...@lists.mozilla.org<mailto:mozilla-dev-s...@lists.mozilla.org>
> Subject: Re: [EXT] Symantec Update on SubCA Proposal
>
>
> Just for clarity:
>
> (Note: Using ISO date format instead of ambiguous local date format)
>
> How many Symantec certs issued prior to 2015-06-01 expire after 2018-
> 06-01, and how does that mesh with the alternative date proposed
> below:
>
> On 18/07/2017 21:37, Steve Medin wrote:

> > Correction: Summary item #3 should read:
> >
> > 3. May 1, 2018
> > a. Single date of distrust of certificates issued prior to 6/1/2016.
> (changed from August 31,2017 for certificates issued prior to 6/1/2015 and
> from January 18, 2018 for certificates issued prior to 6/1/2016).
> >

Over 34,000 certificates were issued prior to 2015-06-01 and expire after 2018-06-01. This is in addition to almost 200,000 certificates that would also need to be replaced under the current SubCA proposal assuming a May 1, 2018 distrust date. We believe that nine months (from August 1, 2017 to May 1, 2018) is aggressive but achievable for this transition — a period minimally necessary to allow for site operators to plan and execute an orderly transition and to reduce the potential risk of widespread ecosystem disruption. Nevertheless, we urge the community to consider moving the proposed May 1, 2018 distrust date out even further to February 1, 2019 in order to minimize the risk of end user disruption by ensuring that website operators have a reasonable timeframe to plan and deploy replacement certificates.



That's pretty close to saying that nothing should happen, since almost all the certificates will have expired by then. That certainly is the least disruptive, but it seems contrary to the intent of the proposal.



-- Eric

_______________________________________________
dev-security-policy mailing list
dev-secur...@lists.mozilla.org<mailto:dev-secur...@lists.mozilla.org>
https://lists.mozilla.org/listinfo/dev-security-policy







--

konklone.com<https://clicktime.symantec.com/a/1/AAH-mYCdy7I540ZoJM0XkW-CDP-fn5bw0sk2P0x4Bvw=?d=U4j3hHTn-UxZ1ZOfHXB7r1lDEq3pYTpkBXJxYkQlk96LvJvpQVJPahGolj9IF9urhtYGsaK_9Mffi6158JvklYeFSEsWRIpnJD82JAbPyGBp6h78ufI4ZGIR8UZNoRVvgyVmB_Lq39lujhD-qOpO1y9E3I2BCtUkhiN98DyEsGpFxqp2JqPiLWxpjzBUBE3IqSdY8Pq0ezPKtY4XG0-7KydvGYIUGOlZJnVxW6_xEJseIlanIDcdA28GGtACgaVDc2QZBHhwpJ8TUK0GgpMW2fu3QdoLf2Fq_yOaeJe1F4AMkzBFTjbk9GF9TNfXVA4dVafUoWb5IFaE6uOy6B6cXKXbZIgX-Ya4lJ0dZ2ZjCSdJSLW2NfhVWxc-FScig3WKjyr-PsV_0lY0ODqzD8M1fhjT-XPzPQ%3D%3D&u=https%3A%2F%2Fkonklone.com> | @konklone<https://twitter.com/konklone>

[Steve Medin]

1) December 1, 2017 is the earliest credible date that any RFP respondent can provide the Managed CA solution proposed by Google, assuming a start date of August 1, 2017. Only one RFP respondent initially proposed a schedule targeting August 8, 2017 (assuming a start date of June 12, 2017). We did not deem this proposal to be credible, however, based on the lack of specificity around our RFP evaluation criteria, as compared to all other RFP responses which provided detailed responses to all aspects of the RFP, and we have received no subsequent information from this bidder to increase our confidence.

2) We are using several selection criteria for evaluating RFP responses, including the depth of plan to address key technical integration and operational requirements, the timeframe to execute, the ability to handle the scope, volume, language, and customer support requirements both for ongoing issuance and for one-time replacement of certificates issued prior to June 1, 2016, compliance program and posture, and the ability to meet uptime, interface performance, and other SLAs. Certain RFP respondents have distinguished themselves based on the quality and depth of their integration planning assumptions, requirements and activities, which have directly influenced the dates we have proposed for the SubCA proposal.

3) The RFP was first released on May 26, 2017. The first round of bidder responses was first received on June 12, 2017.

4) It is our longstanding policy not to comment on rumors or market speculation.

From: Alex Gaynor [mailto:aga...@mozilla.com]
Sent: Wednesday, July 19, 2017 10:25 AM
To: Steve Medin <Steve...@symantec.com>
Cc: mozilla-dev-s...@lists.mozilla.org
Subject: Re: [EXT] Symantec Update on SubCA Proposal

[Gervase Markham]

Hi Steve,

Thanks for posting this. I appreciate the level of detail provided,
which is useful in giving us a basis for discussion. It's a little
regrettable, though, that it was published a couple of weeks after we
were led to expect it...

One note before we start: Symantec's business dealings regarding its CA
business are not of concern to Mozilla other than relating to the
"change of ownership or control" provisions in Mozilla policy (policy
2.5 section 8). However, if dates are proposed or agreed for
implementation of the consensus plan, we would not expect those dates to
be renegotiated because of a change of ownership or control.

Am I right in saying that, in order to hit these dates you are
proposing, you would strongly desire to get consensus on them by August 1st?

On 18/07/17 19:22, Steve Medin wrote:
> New Certificate Issuance: We believe the dates for transition of validation and issuance to the Managed CA that are both aggressive and achievable are as follows:
>
> - Implement the Managed CA by December 1, 2017 (changed from August 8, 2017);
>
> - Managed CA performs domain validation for all new certificates by December 1, 2017 (changed from November 1, 2017); and
>
> - Managed CA performs full validation for all certificates by February 1, 2018. Prior to this date, reuse of Symantec authenticated organization information would be allowable for certificates of <13 months in validity.

To summarise for those reading along: this represents a change of a
little less than 4 months for the first date, 1 month for the second
date, and the third date is as originally proposed.

Steve: to be clear, this means that browsers could implement a block on
certificates from Symantec's existing PKI as follows: after December
1st, 2017, they could dis-trust all certificates with a notBefore
greater than December 1st 2017?

Given the explanations Symantec has given as to why these dates are
reasonable, and the effort required to stand up the new PKI, I am minded
to accept them, particularly as they have managed to hit the third
originally-proposed date on the nose. However, I am still open to
community input.

> Replacement of Unexpired Certificates Issued Before June 1, 2016: There are two major milestones that must be achieved after implementation of the Managed CA in order to replace unexpired certificates issued before June 1, 2016 that do not naturally expire before the distrust date(s) in the SubCA proposal. Those include the full revalidation of certificate information and then the customer replacement of those certificates.

That is not necessarily so. The customers could replace their
certificates using new, CT-logged certificates from Symantec's old
infrastructure. This doesn't require any revalidation or any change in
the certificate chain, so should have excellent compatibility
properties, and it's something that could begin today. In fact, as I
understand it, Symantec has already been encouraging their customers to
do exactly this.

This would, of course, mean, that those certificates would need
replacing again at some point before the final total dis-trust of the
current Symantec PKI.

This activity would need to start during the December holiday season
when many organizations impose infrastructure blackout periods. As
such, we believe that the only achievable timing for this transition is
after the holiday season. We understand that browsers may want to
technically enforce this transition and that multiple milestones may be
undesirable from a coding perspective. In order to accommodate a
simplified and cost efficient transition schedule (especially for
organizations that currently have certificates with notBefore dates of
both June 1, 2015 and June 1, 2016) and to allow impacted organizations
the time, as they will likely need to replace, test and operationalize
these replacement certificates in their infrastructure, we recommend
consolidating Chrome's distrust dates to a single date of May 1, 2018.
This would mean that Chrome's distrust of Symantec certificates issued
before June 1, 2015 would change from August 31, 2017 to May 1, 2018,
and that Chrome's distrust of Symantec certificates issued before June
1, 2016 would change from January 18, 2018 to May 1, 2018.

A key date for Mozilla is when we can tell our software to dis-trust any
certificate issued by the Symantec current PKI which was issued before
June 1st 2016, because certificates issued after that are guaranteed
(pretty much) to be in CT, and therefore are a bounded and known set.
Therefore pushing that date out to May 1st 2018 seems like a negative
from our perspective.

A two-stage strategy such as the one outlined above seems to us to be
worth investigating, as it would allow us to give Symantec more time to
transition its customers from the current to the new PKI (something
which might come with compatibility risk, as you have correctly noted)
without having to bear the risk of continuing to trust arbitrary and
unbounded sections of the current PKI.

So I would like to propose an alternative timeline based on those
principles. The exact dates could be discussed, but it might work
something like this:

December 1st, 2017: Dis-trust of all current PKI certificates issued
before June 1st, 2016. This means all Symantec customers with certs
older than this would need to implement a certificate change in the next
four months, but they could do so to near-identical certificates issued
from the same roots, intermediates and infra, a prospect which should
have excellent compatibility characteristics. Why December 1st? Well, it
matches with the other December 1st date (for standing up the new PKI),
and extending further beyond that seems to provide little value given
the holiday change freeze issue that is regularly raised.

November 1st, 2018: Total dis-trust of the current Symantec PKI. This
gives Symantec the full nine month window that you have requested (from
Feb 1, the target date for Managed CAs to be able to do validation, to
Nov 1) to transition their customers from the old PKI to the new PKI,
with new validations done by the Managed CA. In an improvement from the
existing plan, this nine months no longer contains a holiday blackout
period, and does not overlap the period when you are focussed on
standing up the new PKI. Mozilla feels more comfortable about allowing
an extended time for this transition because the set of old PKI
certificates that would need be trusted during this period would be
known and bounded because they would all be in CT.

I would like Symantec to seriously consider and comment on the
feasibility of a plan structured along these lines.

> We've also received feedback from some of our prospective Managed CA partners that they would like Symantec validation staff to continue to perform verification of identity under the baseline requirements. The Managed CA would complete all domain validation and they would make the final decision on certificate issuance. In this scenario, Symantec would continue to undertake a baseline requirement audit and WebTrust audit for as long as it operates that particular RA function. Permitting Symantec to perform just the organizational validation (not the domain validation) would give customers an uninterrupted experience while still meeting the stated objectives. We look forward to community feedback on this proposed change to the SubCA proposal.

I think I prefer the proposal where Symantec staff work under the aegis
of the Managed CA, it is responsible for them, and they report to it.

Note that I am on holiday for a further week, but will try and check in
here from time to time.

Gerv

[Rick Andrews]

On Thursday, July 20, 2017 at 12:31:56 PM UTC-7, Gervase Markham wrote:
> Hi Steve,
>
> Thanks for posting this. I appreciate the level of detail provided,
> which is useful in giving us a basis for discussion. It's a little
> regrettable, though, that it was published a couple of weeks after we
> were led to expect it...

In our June 1 post, we stated that we would update the community after the end of the month. Considering the community’s request for detail in our response, we wanted our update to reflect our latest discussions with RFP respondents, which took place during the first two weeks of July. These discussions have directly informed our proposed dates as described in our post. We also felt it was important to collect feedback from both Google and Mozilla (which we have done) on our draft timing proposal before submitting it to the community for consideration given that Google and Mozilla authored / endorsed the SubCA proposal.

> One note before we start: Symantec's business dealings regarding its CA
> business are not of concern to Mozilla other than relating to the
> "change of ownership or control" provisions in Mozilla policy (policy
> 2.5 section 8). However, if dates are proposed or agreed for
> implementation of the consensus plan, we would not expect those dates to
> be renegotiated because of a change of ownership or control.
>
> Am I right in saying that, in order to hit these dates you are
> proposing, you would strongly desire to get consensus on them by August 1st?

Symantec would like to reach consensus on the totality of the SubCA proposal, including final dates, as soon as possible. This is in the best interest of all. Our proposed dates assume we are able to finalize negotiation of contracts with the selected Managed CA partner(s), which incorporate final agreed-upon dates by the community, by no later than July 31, 2017.

> On 18/07/17 19:22, Steve Medin wrote:
> > New Certificate Issuance: We believe the dates for transition of validation and issuance to the Managed CA that are both aggressive and achievable are as follows:
> >
> > - Implement the Managed CA by December 1, 2017 (changed from August 8, 2017);
> >
> > - Managed CA performs domain validation for all new certificates by December 1, 2017 (changed from November 1, 2017); and
> >
> > - Managed CA performs full validation for all certificates by February 1, 2018. Prior to this date, reuse of Symantec authenticated organization information would be allowable for certificates of <13 months in validity.
>
> To summarise for those reading along: this represents a change of a
> little less than 4 months for the first date, 1 month for the second
> date, and the third date is as originally proposed.

This is correct. We have worked with our RFP respondents to put together an aggressive but achievable plan that delivers on the spirit of the original proposal.

> Steve: to be clear, this means that browsers could implement a block on
> certificates from Symantec's existing PKI as follows: after December
> 1st, 2017, they could dis-trust all certificates with a notBefore
> greater than December 1st 2017?

Correct. However, as we indicated in our update, with a change of this magnitude we believe that there will likely be material compatibility and interoperability issues that will only come to light once server operators begin the transition to the Managed CA issued certificates. Recognizing this, we recommend that we establish a clear process to evaluate exception requests that includes consultations with the browsers to handle such corner cases.

> Given the explanations Symantec has given as to why these dates are
> reasonable, and the effort required to stand up the new PKI, I am minded
> to accept them, particularly as they have managed to hit the third
> originally-proposed date on the nose. However, I am still open to
> community input.
>
> > Replacement of Unexpired Certificates Issued Before June 1, 2016: There are two major milestones that must be achieved after implementation of the Managed CA in order to replace unexpired certificates issued before June 1, 2016 that do not naturally expire before the distrust date(s) in the SubCA proposal. Those include the full revalidation of certificate information and then the customer replacement of those certificates.
>
> That is not necessarily so. The customers could replace their
> certificates using new, CT-logged certificates from Symantec's old
> infrastructure. This doesn't require any revalidation or any change in
> the certificate chain, so should have excellent compatibility
> properties, and it's something that could begin today.

While this is true under the terms of the SubCA proposal, we do not believe this is consistent with the spirit of Google’s and Mozilla’s prior commentary on their intent regarding the SubCA proposal, which is to limit the issuance of Symantec certificates under Symantec’s existing infrastructure and governance. While we continue to believe the SubCA proposal is unnecessary and unwarranted, our primary objective has always been to minimize any potential business disruption for our customers and for browser users while also responding to Google’s and Mozilla’s comments about Symantec certificates and our issuance practices, which is why we have previously indicated our willingness to adopt the SubCA proposal with appropriate modifications, such as achievable dates. Accordingly, our intention and expectation is that the majority of certificates issued before June 1, 2016 that will need to be replaced before their expiration under the current SubCA proposal will occur after the Managed CA is implemented. This will ensure there are no limitations on the replacement certificates that are issued to affected customers, which limits the substantial risks of implementation problems if our customers are not given the appropriate time to plan and execute their certificate replacements. In our post we explained our rationale of why this period needs to be a minimum of 9 months. It is important for the community to note the significant operational burden and compatibility / interoperability risks that our customers will face if they have to replace their certificates once, let alone twice.

> In fact, as I
> understand it, Symantec has already been encouraging their customers to
> do exactly this.

Symantec has received significant inbound requests from customers about whether or not they should be replacing their certificates issued before June 1, 2016 based on the dates of Google’s original SubCA proposal. To allay concerns, which were compounded by predatory statements by some of our competitors, Symantec sent a message to customers explaining how to replace their certificates now as a preventative and risk mitigation measure. In that outreach, we were clear, as Google and Mozilla have been, that the SubCA proposal was still a proposal and not an agreed upon plan that required customer action.

> This would, of course, mean, that those certificates would need
> replacing again at some point before the final total dis-trust of the
> current Symantec PKI.

Correct. This increases business disruption and interoperability and compatibility risk, which is why we do not believe a December 1, 2017 distrust date is feasible or constructive (more on that below). Assuming the final SubCA plan implements a May 1, 2018 distrust date for certificates issued before June 1, 2016, we will recommend to customers that they begin planning their replacement of unexpired certificates once the SubCA proposal becomes an agreed-upon plan. We will further recommend to customers that they schedule the actual replacement of such unexpired certificates, where possible, for a date that is after full implementation of the Managed CA (February 1, 2018) so they can execute early replacement of their Symantec certificates issued before June 1, 2016 with new certificates that will be valid for the lifetime they require (within the scope of the BRs). We believe organizations will need up to 9 months to safely plan for and carry out this unscheduled transition. Our recommendation for replacing certificates issued before June 1, 2016 by May 1, 2018 (and preferably by February 1, 2019) enables a single shift to our new PKI for SSL/TLS certificates and eliminates any necessity for organizations to replace their certificates multiple times.

We believe a suggestion to implement a December 1, 2017 distrust date for certificates issued before June 1, 2016 and a total distrust date of November 30, 2018 for Symantec PKI for SSL/TLS is contrary to a fundamental principle underlying the SubCA proposal and substantially increases Internet ecosystem disruption and compatibility / interoperability risk.

The practical effect of this suggestion is to require up to two early replacements for affected customers of certificates issued before June 1, 2016 and a newly introduced early replacement cycle for customers of certificates issued between June 1, 2016 and December 1, 2017, the proposed date of transition to the Managed CA. This suggestion increases compatibility and interoperability risk, and causes substantially increased disruption to websites and web end-users.

A December 1, 2017 distrust date for certificates issued before June 1, 2016 effectively prevents Symantec from issuing replacement certificates on the Managed CA infrastructure, which is contrary to what we have been led to believe was the original purpose of the SubCA proposal made by Google and Mozilla. Symantec has done extensive work to propose what we believe is the most aggressive timeline for both migration to the Managed CA(s) and the distrust of certificates issued before June 1, 2016 that is also achievable and safe. The earliest distrust date that is both aggressive and achievable is May 1, 2018 for Symantec SSL/TLS certificates issued before June 1, 2016. In fact, we urge the community to consider postponing this to as late as February 1, 2019. Our proposed 9-month period (from August 1, 2017 to May 1, 2018) is significantly more aggressive than other extraordinary events that have involved early certificate replacement, such as the years of transition to 2048 bit and SHA-256 certificates (the only relevant comparisons for an effort of this magnitude). Further, the most practical period for customers to time their changes to minimize further disruption will be after we have implemented full validation with the Managed CA, which we propose to be no later than February 1, 2018. This leaves effectively 3 months for our affected customers to test and implement replacement certificates assuming they schedule their replacements during this window.

The introduction of a new “total distrust” condition to the SubCA proposal – a November 1, 2018 total distrust date for Symantec’s PKI for SSL/TLS – creates a new distrust event for Symantec customers of unexpired certificates issued between June 1, 2016 and December 1, 2017, the proposed date of transition to the Managed CA, which significantly expands the scope of total Internet ecosystem disruption under the SubCA proposal. Further, this “total distrust” condition, when combined with the December 1, 2017 distrust date suggestion for certificates issued before June 1, 2016, necessarily creates a second early replacement cycle for the new certificates that are issued as a replacement of unexpired certificates issued before June 1, 2016. That’s a punitive result for customers that replace such unexpired, pre-June 1, 2016 issued certificates with new Symantec certificates. Multiple, premature replacements will also increase confusion and compound the possibility of mistakes during customer implementation.

More importantly, however, this newly introduced “total distrust” date condition to the SubCA proposal is completely contrary to a fundamental principle of the original SubCA proposal authored by Google and endorsed by Mozilla, which Symantec has relied upon in good faith in evaluating whether and how to implement the SubCA proposal – namely, that “existing certificates issued on or after June 1st 2016 would still be trusted, provided they comply with the Chrome CT policy.” On May 23, 2017, Google confirmed on Blink that Symantec certificates issued after June 1, 2016 would not be “be constrained in any way (such as reduced validity, no EV treatment, etc.).” On July 7, 2017, Mozilla confirmed on Blink: “Mozilla continues to support the proposal as originally written (with the exception of questions about timeline, which remain to be agreed).”

Simply put, this total distrust date suggestion introduces a new condition to the SubCA proposal that is uniquely punitive to Symantec’s CA business and to Symantec customers, is unjustified, and materially alters a fundamental tenet of the original SubCA proposal, which Mozilla has publicly endorsed as recently as July 7, 2017 and which Symantec and its prospective Managed CA partner(s) have relied upon in all of our discussions and SubCA planning efforts to date.

In light of all of these implications, we respectfully request that Mozilla, Google and the community consider the dates Symantec has proposed, which are the results of our earnest and extensive efforts to implement the spirit of the SubCA proposal.

[Gervase Markham]

On 21/07/17 07:00, Rick Andrews wrote:
> In light of all of these implications, we respectfully request that Mozilla, Google and the community consider the dates Symantec has proposed, which are the results of our earnest and extensive efforts to implement the spirit of the SubCA proposal.

Thank you for the timeliness and completeness of your response. I am
travelling today, but will try and consider it over the weekend.

Gerv

[Alex Gaynor]

On Thu, Jul 20, 2017 at 11:00 AM, Steve Medin <Steve...@symantec.com>
wrote:

> 1) *December 1, 2017 is the earliest credible date that any RFP

> respondent can provide the Managed CA solution proposed by Google, assuming
> a start date of August 1, 2017. Only one RFP respondent initially proposed
> a schedule targeting August 8, 2017 (assuming a start date of June 12,
> 2017). We did not deem this proposal to be credible, however, based on the
> lack of specificity around our RFP evaluation criteria, as compared to all
> other RFP responses which provided detailed responses to all aspects of the
> RFP, and we have received no subsequent information from this bidder to

> increase our confidence.*
>
>
Hi Steve,

Given that this represents nearly a 4 month difference in timelines, can
you give us any more insight here as why you see such a large delta?

Alex

[Peter Bowen]

Steve,

I think this level of public detail is very helpful when it comes to
understanding the proposal.

On Thu, Jul 20, 2017 at 8:00 AM, Steve Medin via dev-security-policy
<dev-secur...@lists.mozilla.org> wrote:
> 1) December 1, 2017 is the earliest credible date that any RFP respondent can provide the Managed CA solution proposed by Google, assuming a start date of August 1, 2017. Only one RFP respondent initially proposed a schedule targeting August 8, 2017 (assuming a start date of June 12, 2017). We did not deem this proposal to be credible, however, based on the lack of specificity around our RFP evaluation criteria, as compared to all other RFP responses which provided detailed responses to all aspects of the RFP, and we have received no subsequent information from this bidder to increase our confidence.

You note that this assumes a start date of June 12. A later email
from Rick Andrews says "Our proposed dates assume we are able to

finalize negotiation of contracts with the selected Managed CA

partner(s), [...] by no later than July 31, 2017."

Presumably the June 12 date is long gone. However if one assumes the
delta of 57 days from start to delivery stands, this would put
delivery at September 26, 2017. This is two months sooner than the
December 1 date. This seems like a pretty big difference. Given you
are asking to delay the timeline based on other RFP respondents being
unable to hit earlier dates, it seems prudent to ask whether the you
attempted to investigate the proposal from the bidder who proposed
August 8.

Given that one of the requirements stated by Google is that the SubCA
operator had to have roots that have been in the Google trust store
for several years, it seems unusual that any eligible respondent would
not be "credible" out of the gate.

Did you ask them to provide more information and details to help
determine if it was a "credible" offer?

> 2) We are using several selection criteria for evaluating RFP responses, including the depth of plan to address key technical integration and operational requirements, the timeframe to execute, the ability to handle the scope, volume, language, and customer support requirements both for ongoing issuance and for one-time replacement of certificates issued prior to June 1, 2016, compliance program and posture, and the ability to meet uptime, interface performance, and other SLAs. Certain RFP respondents have distinguished themselves based on the quality and depth of their integration planning assumptions, requirements and activities, which have directly influenced the dates we have proposed for the SubCA proposal.
>
> 3) The RFP was first released on May 26, 2017. The first round of bidder responses was first received on June 12, 2017.

In the https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/ovLalSBRBQAJ
message, it was implied that Symantec was aware of the SubCA plan and
dates since at least May 12. Given the plan to sign an agreement by
July 31, the August 8 date seems rather impossible. Did Symantec push
back on the August 8 date at that point?

In the original email that started this subthread, you said, "Some of

the prospective Managed CAs have proposed supporting only a portion of
our volume (some by customer segment, others by geographic focus), so
we are also evaluating options that involve working with multiple
Managed CAs."

Have you considered a staggered date system for different classes of
certificates. For example, I would assume that certificates that
don't contain subject identity information would have less work for
migration integration than EV certificates. Given that it is common
practice to have a different SubCA for different certificates types,
could you hit an earlier date for non-EV certificates and then later
have the EV SubCA ready?

Thanks,
Peter

[Rick Andrews]

On Friday, July 21, 2017 at 12:07:02 PM UTC-7, Alex Gaynor wrote:

We have evaluated the rigor of the proposals with regard to integration between Symantec and the Managed CA(s) for all certificate lifecycle functions for retail, partner, and Enterprise RA models, supporting enrollment, all methods of domain verification, organization and extended validation vetting, re-authentication, replacement, renewal, cancelation, modification, revocation, CAA checking, CT logging, and CRL and OCSP response provisioning; the models for cross-team engagement and release planning; identification of any gaps and the plans to address; and the plans for end-to-end testing. The most aggressive of the RFP responses was the sole outlier in terms of timing (2 months to implementation) and offered the least amount of information in response to the RFP. There were other attributes relating to this bidder’s proposal beyond its lack of content in addressing RFP evaluation criteria that reinforced our conclusion that the bid was not realistic. The difference between the most aggressive timing proposal when compared with the other RFP respondent plans was only about two months. All other RFP responses independently offered project plan timelines that spanned approximately 4-6 months. Symantec’s internal planning concluded that a 4 month timeline was aggressive but achievable.

[Rick Andrews]

On Friday, July 21, 2017 at 12:39:54 PM UTC-7, Peter Bowen wrote:
> Steve,
>
> I think this level of public detail is very helpful when it comes to
> understanding the proposal.
>
> On Thu, Jul 20, 2017 at 8:00 AM, Steve Medin via dev-security-policy

> wrote:
> > 1) December 1, 2017 is the earliest credible date that any RFP respondent can provide the Managed CA solution proposed by Google, assuming a start date of August 1, 2017. Only one RFP respondent initially proposed a schedule targeting August 8, 2017 (assuming a start date of June 12, 2017). We did not deem this proposal to be credible, however, based on the lack of specificity around our RFP evaluation criteria, as compared to all other RFP responses which provided detailed responses to all aspects of the RFP, and we have received no subsequent information from this bidder to increase our confidence.
>
> You note that this assumes a start date of June 12. A later email
> from Rick Andrews says "Our proposed dates assume we are able to
> finalize negotiation of contracts with the selected Managed CA
> partner(s), [...] by no later than July 31, 2017."
>
> Presumably the June 12 date is long gone. However if one assumes the
> delta of 57 days from start to delivery stands, this would put
> delivery at September 26, 2017. This is two months sooner than the
> December 1 date. This seems like a pretty big difference. Given you
> are asking to delay the timeline based on other RFP respondents being
> unable to hit earlier dates, it seems prudent to ask whether the you
> attempted to investigate the proposal from the bidder who proposed
> August 8.

Please see our response to Alex Gaynor.

> Given that one of the requirements stated by Google is that the SubCA
> operator had to have roots that have been in the Google trust store
> for several years, it seems unusual that any eligible respondent would
> not be "credible" out of the gate.
>
> Did you ask them to provide more information and details to help
> determine if it was a "credible" offer?

There is a difference between a prospective SubCA being capable of performing the activities of a Managed CA under the SubCA proposal and having a realistic plan to do so. We concluded the RFP response from the sole respondent who proposed a 2-month timeline was not credible because it failed to meet a minimum bar of providing us with sufficient information to evaluate the bidder’s ability to satisfy RFP requirements or meaningfully compare / contrast the bidder’s response with all other RFP respondents. There were other attributes relating to this bidder’s proposal beyond its lack of content in addressing RFP evaluation criteria that reinforced our conclusion that the bid was not credible.

> > 2) We are using several selection criteria for evaluating RFP responses, including the depth of plan to address key technical integration and operational requirements, the timeframe to execute, the ability to handle the scope, volume, language, and customer support requirements both for ongoing issuance and for one-time replacement of certificates issued prior to June 1, 2016, compliance program and posture, and the ability to meet uptime, interface performance, and other SLAs. Certain RFP respondents have distinguished themselves based on the quality and depth of their integration planning assumptions, requirements and activities, which have directly influenced the dates we have proposed for the SubCA proposal.
> >
> > 3) The RFP was first released on May 26, 2017. The first round of bidder responses was first received on June 12, 2017.
>
> In the https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/ovLalSBRBQAJ
> message, it was implied that Symantec was aware of the SubCA plan and
> dates since at least May 12. Given the plan to sign an agreement by
> July 31, the August 8 date seems rather impossible. Did Symantec push
> back on the August 8 date at that point?

Yes, Symantec pushed back on the August 8 date in its earliest discussions with both Google and Mozilla after the SubCA proposal was made. We pushed back on the dates again publicly on June 1st. We have now done the work of executing a robust RFP process that included multiple parties and involved multiple working sessions to arrive at dates that are both aggressive and achievable for the size and scale of our CA operations.

> In the original email that started this subthread, you said, "Some of
> the prospective Managed CAs have proposed supporting only a portion of
> our volume (some by customer segment, others by geographic focus), so
> we are also evaluating options that involve working with multiple
> Managed CAs."
>
> Have you considered a staggered date system for different classes of
> certificates. For example, I would assume that certificates that
> don't contain subject identity information would have less work for
> migration integration than EV certificates. Given that it is common
> practice to have a different SubCA for different certificates types,
> could you hit an earlier date for non-EV certificates and then later
> have the EV SubCA ready?

Yes, we are discussing the specific deployment schedules with RFP respondents with an eye towards fastest time to market where feasible and avoiding a single “big bang” go live date if possible. We believe implementing any additional intermediate “must hit” external deadlines is not constructive given the extent of the technical undertaking — we will need to maintain internal development schedule flexibility to address gaps that are identified along the way. December 1, 2017 is an aggressive but achievable date by which to implement the Managed CA according to the scope of the current SubCA proposal.

[Gervase Markham]

Hi Rick,

Some more thoughts on your post. I continue to invite community
commentary on the issues we are discussing.

On 21/07/17 07:00, Rick Andrews wrote:

> In our June 1 post, we stated that we would update the community after the end of the month.

Indeed. I was more referring to the suggestions made in the meeting with
Mozilla about when the public statement would be forthcoming. But no matter.

> Correct. However, as we indicated in our update, with a change of
> this magnitude we believe that there will likely be material
> compatibility and interoperability issues that will only come to
> light once server operators begin the transition to the Managed CA
> issued certificates. Recognizing this, we recommend that we establish
> a clear process to evaluate exception requests that includes
> consultations with the browsers to handle such corner cases.

Operators who have initial difficulty with the transition can, of
course, stay on their certificates issued from the old infrastructure.
(It's worth noting that if all of those customers had recently renewed
their certificates, as my proposal suggests, then there would not be a
problem with their existing-infra certs expiring while they were
attempting to make the transition.)

How would you see such an exception process working, and how would it be
implemented technically?

> While this is true under the terms of the SubCA proposal, we do not
> believe this is consistent with the spirit of Google’s and Mozilla’s
> prior commentary on their intent regarding the SubCA proposal, which
> is to limit the issuance of Symantec certificates under Symantec’s
> existing infrastructure and governance.

I'm not sure how you reach that conclusion. We want to end new issuance
in December, you want it to continue until next May. How are our dates
more inconsistent than yours with a desire to limit the issuance of
Symantec certificates under the existing infrastructure and governance?
We want to limit it earlier.

> dates. Accordingly, our intention and expectation is that the
> majority of certificates issued before June 1, 2016 that will need to
> be replaced before their expiration under the current SubCA proposal
> will occur after the Managed CA is implemented. This will ensure
> there are no limitations on the replacement certificates that are
> issued to affected customers, which limits the substantial risks of
> implementation problems if our customers are not given the
> appropriate time to plan and execute their certificate replacements.

It may be appropriate for the limitations on current-infra issuance
lifetime in the plan to be adjusted by a few months such that a
certificate issued now can continue to work until the full distrust date
of November 1st, 2018. This would effectively mean that there are no
(additional) limitations on the replacement certificates.

> In our post we explained our rationale of why this period needs to be
> a minimum of 9 months. It is important for the community to note the
> significant operational burden and compatibility / interoperability
> risks that our customers will face if they have to replace their
> certificates once, let alone twice.

Why do you see a compatibility and interoperability risk in the process
of replacing a certificate with an identical certificate except that is
a) definitely logged to CT, and b) has a later expiry date?

You may argue that it's a customer operational burden but again, if
customers have difficulty replacing their SSL certs in a 4-month
timeframe, then they are not well positioned to deal with a number of
potential crises in the SSL system, such as compromise (and distrust) of
an intermediate, or compromise of their webservers.

> Our recommendation for replacing certificates issued before June 1,
> 2016 by May 1, 2018 (and preferably by February 1, 2019) enables a
> single shift to our new PKI for SSL/TLS certificates and eliminates
> any necessity for organizations to replace their certificates
> multiple times.

As noted above, I am not particularly impressed by arguments that
"replacing our certificates twice in 2-3 years is too hard".

It's also worth noting that in the timeline you propose, organizations
would have only 5 months (Dec 1 2017 - May 1 2018), including the
holiday period, to test and deploy the actual certificates they would be
using from the Managed CAs - those which do carry compatibility risk.
And it's only 3 months if they want to replace with fully-validated
non-DV certificates. My plan allows 9 uninterrupted months for that,
which gives significantly more scope to deal with unexpected
compatibility problems caused by new algorithms, new chains, etc. etc.
If customers are asking for time to manage a transition to a new
hierarchy, and that is your key concern, the plan I am proposing gives
them significantly more of it than yours does.

> The practical effect of this suggestion is to require up to two early
> replacements for affected customers of certificates issued before
> June 1, 2016

I think you are overstating this somewhat. Given the industry move to
2-year lifetimes, many customers would have needed to make at least one
replacement during the period concerned anyway.

> The earliest distrust date that is both aggressive and achievable is
> May 1, 2018 for Symantec SSL/TLS certificates issued before June 1,
> 2016.

That is only true with a particular set of assumptions and goals; as
noted early in the process, it is not necessarily the case that Mozilla
will share or agree with all of Symantec's assumptions and goals, and
this might lead to differing views of what is appropriate. This may be
what is happening now.

There is a trade-off here between inconvenience to Symantec and, to some
degree, to its customers in requiring cert replacements, and the
security risks of continuing to trust Symantec's current PKI. It is
understandable that there is a difference of opinion between Symantec
and Mozilla as to how best to manage that trade-off.

> The introduction of a new “total distrust” condition to the SubCA
> proposal – a November 1, 2018 total distrust date for Symantec’s PKI
> for SSL/TLS

I must push back on the suggestion that this is a new idea. Mozilla has
said since the beginning that we are keen to close the door on
Symantec's current PKI, and would wish to do so some time during 2018 at
the very latest. We made this clear in the message "Mozilla requirements
of Symantec" posted to m.d.s.p. and Steve Medin on 7th June 2017.
https://groups.google.com/d/msg/mozilla.dev.security.policy/C45hQChFLyc/lC46UTnnAAAJ
.. November 1st 2018 is fairly late in 2018 already. This was also, I
believe, brought up in the face-to-face meeting we had.

This also made the point that Mozilla is not currently able to make
CT-based decisions as Google is, and so continued trust based on CT
logging may not be an option for us.

> That’s a punitive result for customers that replace such unexpired,
> pre-June 1, 2016 issued certificates with new Symantec certificates.

If having to replace one's certificates is as strong as "punitive", then
there's something very wrong, and it's not Mozilla's policy.

> More importantly, however, this newly introduced “total distrust”
> date condition to the SubCA proposal is completely contrary to a
> fundamental principle of the original SubCA proposal authored by
> Google and endorsed by Mozilla, which Symantec has relied upon in
> good faith in evaluating whether and how to implement the SubCA
> proposal – namely, that “existing certificates issued on or after
> June 1st 2016 would still be trusted, provided they comply with the
> Chrome CT policy.” On May 23, 2017, Google confirmed on Blink that
> Symantec certificates issued after June 1, 2016 would not be “be
> constrained in any way (such as reduced validity, no EV treatment,
> etc.).” On July 7, 2017, Mozilla confirmed on Blink: “Mozilla
> continues to support the proposal as originally written (with the
> exception of questions about timeline, which remain to be agreed).”

That sentence was in the context of Symantec's proposed changes to the
proposal, which we had evaluated and decided not to proceed with.
Mozilla has always, as noted above, made it clear that we wish to close
the door on Symantec's current PKI some time in 2018.

This intention was signalled and the Mozilla full-distrust date of Nov
1st 2018 is pretty late for "some time in 2018". So that date cannot be
the cause of the disquiet. The December 1st suggested date for the
ceasing of issuance from Symantec's existing PKI would need to be agreed
by other participants in the plan, and may have to be tweaked to fit
better with particular release dates for the various browsers involved;
so perhaps we should wait to hear what they have to say.

Gerv

[Rick Andrews]

On Monday, July 24, 2017 at 2:50:22 AM UTC-7, Gervase Markham wrote:
> Hi Rick,
>
> Some more thoughts on your post. I continue to invite community
> commentary on the issues we are discussing.
>
> On 21/07/17 07:00, Rick Andrews wrote:
> > In our June 1 post, we stated that we would update the community after the end of the month.
>
> Indeed. I was more referring to the suggestions made in the meeting with
> Mozilla about when the public statement would be forthcoming. But no matter.
>
> > Correct. However, as we indicated in our update, with a change of
> > this magnitude we believe that there will likely be material
> > compatibility and interoperability issues that will only come to
> > light once server operators begin the transition to the Managed CA
> > issued certificates. Recognizing this, we recommend that we establish
> > a clear process to evaluate exception requests that includes
> > consultations with the browsers to handle such corner cases.
> Operators who have initial difficulty with the transition can, of
> course, stay on their certificates issued from the old infrastructure.
> (It's worth noting that if all of those customers had recently renewed
> their certificates, as my proposal suggests, then there would not be a
> problem with their existing-infra certs expiring while they were
> attempting to make the transition.)

In practice, this is much more difficult. For larger organizations, PKI administration is often a dedicated function where administrators may have limited visibility into the applications using specific certificates. This makes communication along the lines of "well, for these types of applications, your existing certificates are fine, but in these others they need a change" much more subject to error and will likely lead to disruption and downtime.

> How would you see such an exception process working, and how would it be
> implemented technically?

The details of this process would probably be best served in a separate thread. Essentially, such a process would involve a quick assessment by the community on the context and merits of the request by the customer, the impact of denying such a request, and a model to actually operationalize such a request (such as potentially white-listing some certificates for a period of time). In the ideal case, these requests that can only be resolved through an exception will not be common, but we believe that we should prepare for such contingencies given the scope of certificates covered, as we have learned with other transitions, such as the SHA1 transition. A placeholder of this type would allow us to reach closure on the operational aspects of the proposal. We can then later begin discussions regarding what such a process would look like.

> > While this is true under the terms of the SubCA proposal, we do not
> > believe this is consistent with the spirit of Google’s and Mozilla’s
> > prior commentary on their intent regarding the SubCA proposal, which
> > is to limit the issuance of Symantec certificates under Symantec’s
> > existing infrastructure and governance.
> I'm not sure how you reach that conclusion. We want to end new issuance
> in December, you want it to continue until next May. How are our dates
> more inconsistent than yours with a desire to limit the issuance of
> Symantec certificates under the existing infrastructure and governance?
> We want to limit it earlier.

We may be more aligned on this point than your response suggests. We are in agreement with you that we will cease issuing certificates under the existing infrastructure and governance on December 1, 2017. At that point you could stop accepting the issuance of new certificates off the existing infrastructure and PKI. (See our last reply to this thread where we confirmed this point, but asked for an exception process.) Our point here is that if you also make December 1, 2017 the "distrust date" for all certificates issued off of Symantec’s current PKI before June 1, 2016 then, in effect, you will be forcing all customers to "double down" on the existing Symantec PKI and infrastructure because they would need to be issued early replacement certificates off of the current PKI. Alternatively, if the distrust date of all certificates issued before June 1, 2016 were to be moved to May 1, 2018 (as opposed to December 1, 2017 as you currently propose) it would allow these replacement certificates to chain to the new PKI because they would be issued by the Managed CA(s) off of the new SubCA(s). This, we believe, was one of the intents of the original proposal which was to move users to the new infrastructure and PKI as quickly as possible. A December 1, 2017 distrust date (for certificates issued before June 1, 2016) would, in practice, have the opposite effect given that none of the replacement certificates could be issued off of the new PKI.

> > dates. Accordingly, our intention and expectation is that the
> > majority of certificates issued before June 1, 2016 that will need to
> > be replaced before their expiration under the current SubCA proposal
> > will occur after the Managed CA is implemented. This will ensure
> > there are no limitations on the replacement certificates that are
> > issued to affected customers, which limits the substantial risks of
> > implementation problems if our customers are not given the
> > appropriate time to plan and execute their certificate replacements.
> It may be appropriate for the limitations on current-infra issuance
> lifetime in the plan to be adjusted by a few months such that a
> certificate issued now can continue to work until the full distrust date
> of November 1st, 2018. This would effectively mean that there are no
> (additional) limitations on the replacement certificates.

We do not understand this comment. According to the SubCA proposal, which Google authored and Mozilla previously endorsed, any replacement certificate issued today off of the existing Symantec PKI will have up to the maximum lifetime currently permitted by the BR's (39 months). Our primary intent around this comment is to highlight that a significant percentage of replacement certificates issued today (e.g., certificates with more than 12 months' validity) will need to be reissued again prematurely if there is a full distrust of the current Symantec WebPKI on November 1, 2018. As an example, consider a website operator that was issued a 39 month certificate on May 1, 2016 -- under your accelerated date proposal, that customer would need to be issued a replacement certificate between today and December 1, 2017 off of Symantec’s current WebPKI. Under that same proposal, they would then need to be issued a second replacement certificate by the Managed CA(s) off the new PKI before November 1, 2018. This would require they support two premature replacements.

> > In our post we explained our rationale of why this period needs to be
> > a minimum of 9 months. It is important for the community to note the
> > significant operational burden and compatibility / interoperability
> > risks that our customers will face if they have to replace their
> > certificates once, let alone twice.
> Why do you see a compatibility and interoperability risk in the process
> of replacing a certificate with an identical certificate except that is
> a) definitely logged to CT, and b) has a later expiry date?
>
> You may argue that it's a customer operational burden but again, if
> customers have difficulty replacing their SSL certs in a 4-month
> timeframe, then they are not well positioned to deal with a number of
> potential crises in the SSL system, such as compromise (and distrust) of
> an intermediate, or compromise of their webservers.

You are correct in that most customers are indeed not prepared to deal with potential crises in the SSL system. We have all witnessed this first hand with Heartbleed, the replacement of SHA1 certificates, etc. A four month replacement window for a forced replacement of this magnitude is unprecedented and we know that things will break. In the recent CA survey, most major CAs reported that replacing certificates annually is something that many organizations are not prepared for – a conclusion that is reinforced by the recent CA/Browser Forum vote rejecting ballot 185, which proposed to limit the maximum validity of SSL/TLS certificates issued by all CAs to 13 months. Do you have data leading you to believe that this replacement can be executed with limited Internet ecosystem disruption, particularly amongst the largest enterprises globally whose certificates would be impacted? If so, we would welcome seeing that data/rationale. The issues that we have all witnessed with other forced replacement events on much longer timelines indicate that the community is not yet at a place of automation to deal with such a transition, especially in a short timeframe. In this case, forcing a distrust date of December 1, 2017 (vs. our May 1, 2018 distrust date recommendation) for certificates issued prior to June 1, 2016 increases the total number of premature replacement certificates that would be need to be issued by approximately 50% and gives website operators substantially less time (4 months vs. 9 months) in which to plan and execute such a replacement. A December 1, 2017 distrust date for certificates issued prior to June 1, 2016 would introduce a known, actual, material risk to the Internet ecosystem given the industry’s prior experience with forced mass replacement episodes. We do not think the perceived benefit of accelerating distrust for Symantec certificates issued before June 1, 2016 from May 1, 2018 to December 1, 2017 (5 months of validity) can possibly justify the significant ecosystem disruption that is likely to result from not accepting our proposed May 1, 2018 distrust date for certificates issued before June 1, 2016. We agree with your public comments on June 19, 2017 that it is not constructive to get into a date-based "negotiation" over the SubCA proposal. We have worked backwards from our best estimate for how long it would take us and our Managed CA partner(s) to implement the SubCA proposal in a manner that allows for an orderly transition of Symantec’s existing PKI infrastructure for SSL/TLS certificates to a Managed CA(s) while minimizing disruption to websites and web end-users, and have proposed aggressive, yet achievable deadlines accordingly. As such, while we are willing to go down the SubCA path overall, we strongly believe that this must be done in a way that aims to minimize website disruption.

> > Our recommendation for replacing certificates issued before June 1,
> > 2016 by May 1, 2018 (and preferably by February 1, 2019) enables a
> > single shift to our new PKI for SSL/TLS certificates and eliminates
> > any necessity for organizations to replace their certificates
> > multiple times.
> As noted above, I am not particularly impressed by arguments that
> "replacing our certificates twice in 2-3 years is too hard".
>
> It's also worth noting that in the timeline you propose, organizations
> would have only 5 months (Dec 1 2017 - May 1 2018), including the
> holiday period, to test and deploy the actual certificates they would be
> using from the Managed CAs - those which do carry compatibility risk.
> And it's only 3 months if they want to replace with fully-validated
> non-DV certificates. My plan allows 9 uninterrupted months for that,
> which gives significantly more scope to deal with unexpected
> compatibility problems caused by new algorithms, new chains, etc. etc.
> If customers are asking for time to manage a transition to a new
> hierarchy, and that is your key concern, the plan I am proposing gives
> them significantly more of it than yours does.

Symantec has proposed timing changes that are consistent with the scope of distrust of the original SubCA proposal as proposed by Google and endorsed by Mozilla, which requires premature replacement of over 234,000 certificates based on our proposed May 1, 2018 distrust date for certificates issued before June 1, 2016, and optimizes for replacement certificates to be issued off the new Managed CA(s) infrastructure (avoiding the requirement for double early replacement for the same original validity period). We believe our proposal minimizes disruption to websites and web end-users while meeting the spirit of Google’s and Mozilla’s prior commentary on their intent regarding the SubCA proposal, which is to limit the issuance of Symantec certificates under Symantec’s existing infrastructure and governance.

In contrast, your suggestion results in an untold impact and millions of Symantec unexpired certificates having to be prematurely re-validated, re-issued and operationally replaced within the next 15 months, with several hundred thousand certificates having to be prematurely replaced with the next 4 months (assuming an August 1, 2017 consensus SubCA plan).

Based on your experience in the PKI world and the feedback that you have received over the years from website operators, do you believe that this significant expansion of the scope of Symantec certificates to be distrusted and subject to premature replacement over the next 15 months minimizes disruption to websites and web end-users?

> > The practical effect of this suggestion is to require up to two early
> > replacements for affected customers of certificates issued before
> > June 1, 2016
> I think you are overstating this somewhat. Given the industry move to
> 2-year lifetimes, many customers would have needed to make at least one
> replacement during the period concerned anyway.

Please see analysis above. Distrusting certificates issued before June 1, 2016 before the Managed CA is in place is indeed forcing up to two early replacements.

> > The earliest distrust date that is both aggressive and achievable is
> > May 1, 2018 for Symantec SSL/TLS certificates issued before June 1,
> > 2016.
> That is only true with a particular set of assumptions and goals; as
> noted early in the process, it is not necessarily the case that Mozilla
> will share or agree with all of Symantec's assumptions and goals, and
> this might lead to differing views of what is appropriate. This may be
> what is happening now.
>
> There is a trade-off here between inconvenience to Symantec and, to some
> degree, to its customers in requiring cert replacements, and the
> security risks of continuing to trust Symantec's current PKI. It is
> understandable that there is a difference of opinion between Symantec
> and Mozilla as to how best to manage that trade-off.

Our proposed timing is not based on avoiding inconvenience to Symantec, but rather managing widespread Internet ecosystem risk and business disruption to our customers and website users from implementation of the original SubCA proposal. By our estimates, Symantec secures up to 80% of the world’s ecommerce transactions through its certificate infrastructure. I believe we at least have the shared goal of not causing widespread disruption and compatibility/interoperability failures for browser users. That shared goal directly translates into implementing a SubCA proposal where our customers, who represent the majority of banking, ecommerce, and other business-oriented sites that users depend on, are given a reasonable path to succeed in this transition. The May 1, 2018 date was carefully calculated to allow this transition to succeed based on the data we discussed in our response. We believe your proposed dates will result in significant Internet ecosystem disruption.

> > The introduction of a new “total distrust” condition to the SubCA
> > proposal – a November 1, 2018 total distrust date for Symantec’s PKI
> > for SSL/TLS
> I must push back on the suggestion that this is a new idea. Mozilla has
> said since the beginning that we are keen to close the door on
> Symantec's current PKI, and would wish to do so some time during 2018 at
> the very latest. We made this clear in the message "Mozilla requirements
> of Symantec" posted to m.d.s.p. and Steve Medin on 7th June 2017.
> https://groups.google.com/d/msg/mozilla.dev.security.policy/C45hQChFLyc/lC46UTnnAAAJ
> .. November 1st 2018 is fairly late in 2018 already. This was also, I
> believe, brought up in the face-to-face meeting we had.
>
> This also made the point that Mozilla is not currently able to make
> CT-based decisions as Google is, and so continued trust based on CT
> logging may not be an option for us.

This is a new idea in the context of the consensus SubCA proposal because it fundamentally disrupts the path of continuity and compatibility that were at the core of the proposal. Distrusting the roots effectively negates core principles of the proposal. Symantec has invested substantial resources in executing against this proposal in good faith. Many other members of the CA community have also invested significant resources in executing against this proposal in good faith as SubCA RFP respondents.

> > That’s a punitive result for customers that replace such unexpired,
> > pre-June 1, 2016 issued certificates with new Symantec certificates.
>
> If having to replace one's certificates is as strong as "punitive", then
> there's something very wrong, and it's not Mozilla's policy.

“Punitive” is our interpretation based on the premature replacements your ideas would impose.

> > More importantly, however, this newly introduced "total distrust"
> > date condition to the SubCA proposal is completely contrary to a
> > fundamental principle of the original SubCA proposal authored by
> > Google and endorsed by Mozilla, which Symantec has relied upon in
> > good faith in evaluating whether and how to implement the SubCA
> > proposal – namely, that “existing certificates issued on or after
> > June 1st 2016 would still be trusted, provided they comply with the
> > Chrome CT policy." On May 23, 2017, Google confirmed on Blink that
> > Symantec certificates issued after June 1, 2016 would not be “be
> > constrained in any way (such as reduced validity, no EV treatment,
> > etc.)." On July 7, 2017, Mozilla confirmed on Blink: "Mozilla
> > continues to support the proposal as originally written (with the
> > exception of questions about timeline, which remain to be agreed)."
> That sentence was in the context of Symantec's proposed changes to the
> proposal, which we had evaluated and decided not to proceed with.
> Mozilla has always, as noted above, made it clear that we wish to close
> the door on Symantec's current PKI some time in 2018.
>
> This intention was signalled and the Mozilla full-distrust date of Nov
> 1st 2018 is pretty late for "some time in 2018". So that date cannot be
> the cause of the disquiet. The December 1st suggested date for the
> ceasing of issuance from Symantec's existing PKI would need to be agreed
> by other participants in the plan, and may have to be tweaked to fit
> better with particular release dates for the various browsers involved;
> so perhaps we should wait to hear what they have to say.

We look forward to the broader community weighing in on this. We urge the community to validate our points, especially the website operators that are being forced to execute this plan. The implementation of a forced plan that introduces material risks on an unrealistic timeline is inappropriate and dangerous. We ask the community to carefully consider again the dates that we have proposed. We believe any other dates could lead to a massive disruption event for browser users and website operators.

[Nick Lamb]

On Tuesday, 25 July 2017 21:29:06 UTC+1, Rick Andrews wrote:
> The details of this process would probably be best served in a separate thread. Essentially, such a process would involve a quick assessment by the community on the context and merits of the request by the customer

You want us to do Symantec's job, for which Symantec will get paid, in order to preserve Symantec's ongoing revenue stream despite Symantec screwing up badly to get themselves into this mess ?

Counter proposal: When a customer runs into such a remarkable "exception", Symantec pays them $5000 or fully refunds their last year of Symantec services, whichever is more, and encourages them to go use the money to choose a different CA where they might not need "exceptions" all the time. Maybe you can get Symantec's lawyers to make acceptance of the $5000 conditional on agreeing not to sue once they understand how much trouble Symantec's incompetence has caused for them.

> We may be more aligned on this point than your response suggests. We are in agreement with you that we will cease issuing certificates under the existing infrastructure and governance on December 1, 2017. At that point you could stop accepting the issuance of new certificates off the existing infrastructure and PKI. (See our last reply to this thread where we confirmed this point, but asked for an exception process.) Our point here is that if you also make December 1, 2017 the "distrust date" for all certificates issued off of Symantec’s current PKI before June 1, 2016 then, in effect, you will be forcing all customers to "double down" on the existing Symantec PKI

No there is no need to "double down". Your customers can and should switch to a CA which doesn't have a long history of "problems" due to inadequate oversight. Trying to retain your customer base is a commercial problem for Symantec, not a Web PKI trust problem. This is not "Keep Symantec being like, totally stoked about, like, the general vibe and stuff".

> We look forward to the broader community weighing in on this. We urge the community to validate our points, especially the website operators that are being forced to execute this plan. The implementation of a forced plan that introduces material risks on an unrealistic timeline is inappropriate and dangerous.

The underlying cause here is Symantec. This isn't a systemic problem, it's a Symantec problem, the only "website operators" affected are those who foolishly trusted Symantec to run a CA properly. A reasonable question for such website operators to ask would be: Where's the press release listing all the board members and other core leadership who were terminated as a result of their failure to execute their only task, providing oversight for the business so that it doesn't blunder into such problems ? Where's the communication from Symantec warning me that their failings may cause my business massive inconvenience and I should begin planning now to move to a different CA to avoid that ?

[Alex Gaynor]

On Tue, Jul 25, 2017 at 4:28 PM, Rick Andrews via dev-security-policy <
dev-secur...@lists.mozilla.org> wrote:

> Symantec has proposed timing changes that are consistent with the scope of
> distrust of the original SubCA proposal as proposed by Google and endorsed
> by Mozilla, which requires premature replacement of over 234,000
> certificates based on our proposed May 1, 2018 distrust date for
> certificates issued before June 1, 2016, and optimizes for replacement
> certificates to be issued off the new Managed CA(s) infrastructure
> (avoiding the requirement for double early replacement for the same

> original validity period). We believe our proposal minimizes disruption to
> websites and web end-users while meeting the spirit of Google’s and

> Mozilla’s prior commentary on their intent regarding the SubCA proposal,
> which is to limit the issuance of Symantec certificates under Symantec’s
> existing infrastructure and governance.
>

Hi Rick,

Given the importance of this 234,000 number, I was curious to explore.
Using the list of certificates Peter Bowen previously put together (
https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/aQqYZX6oBgAJ),
I ran a small script to filter out ones that expire before May 2018, or
were issued after June 2016. Using this methodlogy, I got a count of 166k,
a deviation of ~70k from your number. My 166k includes any certificates
that have been replaced since Peter put together the list in April, so in
that sense it likely reflects an over estimate of the number of certs
needing to be replaced.

Can you say a little more on how you came to this number?

Cheers,
Alex

[Jakob Bohm]

On 25/07/2017 22:28, Rick Andrews wrote:
> ...

Where exactly was it suggested to distrust certificates issued before
Jun 1, 2016 on December 1, 2017?

So far most of the discussion seems to have been about distrusting
Symantec certs issued after December 1, 2017, at least as I read it.

[Rick Andrews]

On Wednesday, July 26, 2017 at 10:20:08 AM UTC-7, Alex Gaynor wrote:
> On Tue, Jul 25, 2017 at 4:28 PM, Rick Andrews via dev-security-policy

Our reference to over 234,000 certificates is based on our internal records of all active, unrevoked certificates that we issued prior to June 1, 2016 that expire after May 1, 2018. The dataset you reference relies on CT logs, which includes all active EV certificates Symantec has issued before June 1, 2016, but does not include all active, unrevoked OV and DV certificates Symantec has issued before June 1, 2016.

[Alex Gaynor]

Just to be explicit: your count includes certificates which, with high
probability have already been replaced, because it does not subtract names
for which new certificates have been issued?

I realize it may seem like I'm putting a lot of emphasis on this one
number, but given that it's the basis for your assertion about the relative
difficulty for different distrust dates, I think it's quite significant.
Given that your methodology appears to over-count (to the advantage of
laxer distrust policies!), and cannot be independently verified, it really
boils down to "trust us to do right by the security of the WebPKI". Not to
put too fine a point on it, but we're in this situation because of
Symantec's history of _not_ acting in the interests of the security of the
WebPKI. It seems to me you could improve the transparency of this process
by logging all DV certs from this time frame to CT.

Alex

On Thu, Jul 27, 2017 at 11:53 AM, Rick Andrews via dev-security-policy <
dev-secur...@lists.mozilla.org> wrote:

> On Wednesday, July 26, 2017 at 10:20:08 AM UTC-7, Alex Gaynor wrote:

> > On Tue, Jul 25, 2017 at 4:28 PM, Rick Andrews via dev-security-policy

> Our reference to over 234,000 certificates is based on our internal
> records of all active, unrevoked certificates that we issued prior to June
> 1, 2016 that expire after May 1, 2018. The dataset you reference relies on
> CT logs, which includes all active EV certificates Symantec has issued
> before June 1, 2016, but does not include all active, unrevoked OV and DV

> certificates Symantec has issued before June 1, 2016.

> _______________________________________________
> dev-security-policy mailing list
> dev-secur...@lists.mozilla.org

> https://lists.mozilla.org/listinfo/dev-security-policy
>

[Devon O'Brien]

Hello m.d.s.p.,

I'd just like to give the community a heads up that Chrome’s plan remains to put up a blog post echoing our recent announcement on blink-dev [1], but in the meantime, we are reviewing the facts related to Symantec’s sale of their PKI business to DigiCert [2].

Recently, it has come to our attention that Symantec may have selected DigiCert from the RFP process to become a Managed CA Partner. As defined in Google’s first Managed CA proposal [3], then supported by Symantec’s commitment to “[cover] all aspects of the SubCA proposal” [4], and finally reiterated in Google’s final proposal [1], the requirement has always been that the Managed Partner Infrastructure be operated by an independent and non-affiliated CA while Symantec worked to rebuild the web community's confidence.

Based on this information, we have a series of questions that we’d like Symantec to address for public discussion:

1. Just to confirm, Did Symantec select DigiCert to be Managed CA Partner under the RFP process? If so, in light of DigiCert’s acquisition of Symantec’s PKI business and Symantec’s substantial equity investment in DigiCert, can you explain how you believe selecting DigiCert as the Managed CA Partner meets the stated requirement of being an independent and non-affiliated organization?

2. Were any additional CAs selected to be a Managed CA Partner from the list of trusted CAs that Symantec “felt best met the browser requirements”?

[1]https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/El1mH8S6AwAJ
[2]http://investor.symantec.com/About/Investors/press-releases/press-release-details/2017/DigiCert-to-Acquire-Symantecs-Website-Security-and-Related-PKI-Solutions/default.aspx
[3]https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/ovLalSBRBQAJ
[4]https://groups.google.com/a/chromium.org/d/msg/blink-dev/eUAKwjihhBs/6iZUc7kOCAAJ

[Steve Medin]

> -----Original Message-----
> From: dev-security-policy [mailto:dev-security-policy-

> bounces+steve_medin=symant...@lists.mozilla.org] On Behalf Of
> Devon O'Brien via dev-security-policy
> Sent: Wednesday, August 09, 2017 12:24 PM
> To: mozilla-dev-s...@lists.mozilla.org

Before we initiated our SubCA RFP process in May, Google provided Symantec with a list of Certificate Authorities, including DigiCert, which met the eligibility requirements of a Managed CA under the SubCA proposal. Symantec conducted a thorough SubCA RFP process and believes DigiCert can credibly meet browser requirements and timelines.

Symantec decided it was in the best interests of all of its stakeholders to sell its Website Security and related PKI solutions to DigiCert. To ensure business continuity for customers, Symantec entered into a SubCA arrangement with DigiCert simultaneous with entry into the definitive acquisition agreement to account for the possibility that the acquisition may not close by December 1, 2017.

Regardless of whether the acquisition closes before December 1, 2017 or not, there is never a circumstance under which DigiCert will be an 'affiliate' of Symantec with respect to acting as Symantec's Managed CA under the SubCA proposal. Symantec currently has no ownership interest in or ability (contractual or otherwise) to control the operations of DigiCert, nor does either party otherwise constitute an 'affiliate' of the other, as such term is defined in the CA-Browser Forum Baseline Requirements (v 1.4.9).

At the closing of the acquisition, Symantec is being paid in both cash and stock, with the latter comprising a 30% ownership interest in the common equity of DigiCert, which allows for Symantec stockholders to benefit from the potential value created by the DigiCert business after the closing. This minority ownership position, which shall not be received by Symantec until the closing of the acquisition, represents a financial investment in DigiCert. This financial investment does not give Symantec control over DigiCert's CA technology, operations or business, and therefore we believe that it satisfies the spirit of the non-affiliate status that the browser community was seeking to achieve through the SubCA proposal.

It is Symantec's understanding that all certificates issued by DigiCert on or after December 1, 2017 and the closing of the acquisition will chain to DigiCert's existing public roots. If the acquisition closes before December 1, 2017, then no certificates will ever be issued by DigiCert as a Managed CA of Symantec because DigiCert will not be issuing certificates under a new ICA that chains to a new Symantec PKI. Rather, in this instance, certificates will either (i) be issued off of Symantec’s existing PKI, which is permitted under the SubCA proposal until November 30, 2017, or (ii) be issued off of DigiCert’s existing PKI. The actual timing of the acquisition closing relative to the parties’ operational integration planning schedule will determine whether certificates are issued under both scenarios or just the latter.

If the acquisition does not close before December 1, 2017, then DigiCert has agreed to serve as Symantec's Managed CA partner as of December 1, 2017, but will not be an 'affiliate' during this pre-closing period for the reasons explained above.

> 2. Were any additional CAs selected to be a Managed CA Partner from the
> list of trusted CAs that Symantec “felt best met the browser requirements”?
>

There were no additional CAs selected to be a Managed CA partner. Symantec conducted a thorough SubCA RFP process and believes DigiCert can credibly meet browser requirements and timelines.

Although we believe the DigiCert transaction achieves the goals of Google and Mozilla and the extended browser community (transition away from Symantec's existing PKI and issuance platform to one that is accepted by browsers) as well as our own goals (minimize customer disruption), there are important differences between this sale transaction and the SubCA proposal. Under the SubCA proposal, Symantec SSL/TLS certificates would be issued through one or more independently operated third-party CAs – under an ICA that chains to a new private PKI issued by Symantec and which is cross-signed by Symantec's existing PKI – until Symantec developed and deployed a modernized PKI platform that is accepted into trust stores. After the closing of the DigiCert acquisition, our customers will be issued SSL/TLS certificates from DigiCert’s existing PKI and platform, which is currently available and publicly trusted by all browsers.

Symantec decided it was in the best interests of all of its stakeholders to sell its Website Security and related PKI solutions to DigiCert because this transaction accelerates the transition for our customers to an existing PKI platform at DigiCert that meets all industry standards and browser requirements, ensuring continuity for our customers and providing a foundation for continued innovation.

[tmcqueen....@gmail.com]

Steve,

Thank you for responding relatively promptly (at least as compared to previous Symantec responses) to Devon's questions.

However, these responses seem to imply that a side effect of the sale *is* to skirt the remediation requirements imposed by Google and Mozilla.

In particular, the agreed upon plan requires issuance (and information verification) by a managed SubCA that does *not* involve Symantec processes, equipment, personnel, etc., until trust in those equipment, people, and processes is established.

if Digicert were *not* acquiring any of the equipment/personnel/processes from Symantec, only the customers, this would seem to meet the spirit and letter of the Symantec remediation plan.

However, the publicly announced details of the acquisition [Devon ref. 2] explicitly state that equipment and personnel will be transferred from Symantec to Digicert. Combined with the answers below, this means that as soon as the deal closes and this transfer occurs, there is no barrier to the formerly-Symantec-but-now-Digicert equipment and personnel from immediately assisting in the issuance of new certificates (presumably under the Digicert roots). This seems to go against the spirit (and possibly letter) of the remediation plan, which was designed to prevent the bad practices within the existing Symantec CA organization from being involved in further issuances until a level of trust could be demonstrated.

Perhaps you or Digicert could clarify why you believe the above to not be the case.

Thank you.

[Nick Lamb]

One good thing we should be able to hope for from a change in ownership even if the personnel and equipment are the same or a great deal in common: improved management oversight. In my view the most worrying underlying problem at Symantec was the inadequate oversight. Senior management at the corporation just can't have been giving this the attention it needs. The sale takes them out of the picture. That's not a great story for Symantec's shareholders, who might reasonably assume that similarly inadequate oversight will continue for the other activities of the business - but it's good news for the Relying Parties.

[Jeremy Rowley]

Hi wizard,

Although DigiCert will acquire the assets related to Symantec’s CA business, DigiCert is not required to use those assets in its business operations. We are organizing the operations of DigiCert to meet the requirements established in the Managed CA proposal. This includes having all validation and issuance performed through DigiCert’s existing PKI and using DigiCert processes accompanied by DigiCert leadership.

Our interpretation of the Google and Mozilla requirements is similar to yours – that the goal is to migrate from Symantec’s existing PKI to a third party while implementing systematic and operational controls over the issuing and validation processes. Post close, we plan to continue towards these objectives using the path adopted by the browsers in the Managed CA process. This path includes regular audits during the transition, a migration away from Symantec’s issuing and validation systems, and implementation of operational controls to prevent mis-issuance. Our plan is to transition completely away from the Symantec issuance platform and validation processes by December 1 and work towards the distrust dates set by Mozilla for the end of 2018.

The Managed CA requirements seemed designed to (1) give Symantec time to reengineer processes and systems and (2) work towards rebuilding trust in the Symantec’s operations. The acquisition eliminates the need to reengineer the process and makes the question of restoring trust moot. With only DigiCert performing the validation and operating the CA, the risks identified to be fixed by the Managed CA proposal are remediated as of closing.

Of course, we’re always open to feedback and additional ideas on how to build community trust. Feel free to message us or submit follow-up questions and ideas about how we can answer the community’s concerns.

Thanks!

Jeremy

-----Original Message-----
From: dev-security-policy [mailto:dev-security-policy-bounces+jeremy.rowley=digice...@lists.mozilla.org] On Behalf Of wizard--- via dev-security-policy
Sent: Friday, August 11, 2017 9:12 PM
To: mozilla-dev-s...@lists.mozilla.org
Subject: Re: Symantec Update on SubCA Proposal

Steve,

Thank you for responding relatively promptly (at least as compared to previous Symantec responses) to Devon's questions.

However, these responses seem to imply that a side effect of the sale *is* to skirt the remediation requirements imposed by Google and Mozilla.

In particular, the agreed upon plan requires issuance (and information verification) by a managed SubCA that does *not* involve Symantec processes, equipment, personnel, etc., until trust in those equipment, people, and processes is established.

if Digicert were *not* acquiring any of the equipment/personnel/processes from Symantec, only the customers, this would seem to meet the spirit and letter of the Symantec remediation plan.

However, the publicly announced details of the acquisition [Devon ref. 2] explicitly state that equipment and personnel will be transferred from Symantec to Digicert. Combined with the answers below, this means that as soon as the deal closes and this transfer occurs, there is no barrier to the formerly-Symantec-but-now-Digicert equipment and personnel from immediately assisting in the issuance of new certificates (presumably under the Digicert roots). This seems to go against the spirit (and possibly letter) of the remediation plan, which was designed to prevent the bad practices within the existing Symantec CA organization from being involved in further issuances until a level of trust could be demonstrated.

Perhaps you or Digicert could clarify why you believe the above to not be the case.

Thank you.

On Friday, August 11, 2017 at 8:32:33 PM UTC-4, Steve Medin wrote:

[Jakob Bohm]

Your below description raises two questions of general interest (though
not of interest to the Mozilla root program):

1. Will DigiCert establish cross-signatures from the old/historic
Symantec roots to continuing DigiCert roots and subCAs?

2. Will DigiCert continue those Symantec services that were not trusted
by Mozilla/Google and which have no functional alternative elsewhere.

This includes a number of situations where Microsoft and other
companies are enforcing that things are signed exclusively by specific
Symantec issuance systems. Known examples include: The original SHA-1
time stamping service for code signing (needed for compatibility with
older Windows and Internet Explorer versions). The special signing
portal for Windows Mobile (the original product line, not the new
renamed Windows 10 Phone product line). The "hosted" signing service
for Android Apps. Possibly any remnants of the Geotrust-based
services for the old Nokia platforms (Symbian S60 etc.). Etc.


NOTICE TO SOME READERS: Please read the first paragraph of this mail!

On 14/08/2017 06:03, Jeremy Rowley wrote:
> Hi wizard,
>
> Although DigiCert will acquire the assets related to Symantec’s CA business, DigiCert is not required to use those assets in its business operations. We are organizing the operations of DigiCert to meet the requirements established in the Managed CA proposal. This includes having all validation and issuance performed through DigiCert’s existing PKI and using DigiCert processes accompanied by DigiCert leadership.
>
> Our interpretation of the Google and Mozilla requirements is similar to yours – that the goal is to migrate from Symantec’s existing PKI to a third party while implementing systematic and operational controls over the issuing and validation processes. Post close, we plan to continue towards these objectives using the path adopted by the browsers in the Managed CA process. This path includes regular audits during the transition, a migration away from Symantec’s issuing and validation systems, and implementation of operational controls to prevent mis-issuance. Our plan is to transition completely away from the Symantec issuance platform and validation processes by December 1 and work towards the distrust dates set by Mozilla for the end of 2018.
>
> The Managed CA requirements seemed designed to (1) give Symantec time to reengineer processes and systems and (2) work towards rebuilding trust in the Symantec’s operations. The acquisition eliminates the need to reengineer the process and makes the question of restoring trust moot. With only DigiCert performing the validation and operating the CA, the risks identified to be fixed by the Managed CA proposal are remediated as of closing.
>
> Of course, we’re always open to feedback and additional ideas on how to build community trust. Feel free to message us or submit follow-up questions and ideas about how we can answer the community’s concerns.
>
>

[Jeremy Rowley]

Hi Jakob,

Your below description raises two questions of general interest (though not of interest to the Mozilla root program):

1. Will DigiCert establish cross-signatures from the old/historic
Symantec roots to continuing DigiCert roots and subCAs?

[JR] We won’t be cross-signing from DigiCert to Symantec. For cross-signs the other way, we plan on supporting the community’s needs and would love to hear more online and offline about what cross-signs to DigiCert are needed for compatibility and interoperability. Mozilla proposed distrusting Symantec’s roots in 2018 so we’ll work towards that goal. Once it’s removed, the one-way trust from Symantec to DigiCert will fall out of scope. Prior to that, the cross-sign will be operated per the BRs and subject to the Google and Mozilla proposals.

2. Will DigiCert continue those Symantec services that were not trusted
by Mozilla/Google and which have no functional alternative elsewhere.

This includes a number of situations where Microsoft and other
companies are enforcing that things are signed exclusively by specific
Symantec issuance systems. Known examples include: The original SHA-1
time stamping service for code signing (needed for compatibility with
older Windows and Internet Explorer versions). The special signing
portal for Windows Mobile (the original product line, not the new
renamed Windows 10 Phone product line). The "hosted" signing service
for Android Apps. Possibly any remnants of the Geotrust-based
services for the old Nokia platforms (Symbian S60 etc.). Etc.

[JR] As you mentioned, none of these are trusted by Mozilla or Google so that discussion is better held elsewhere. However, I can say that we plan to support Symantec communities to the extent possible. The only planned deprecation is the Symantec publicly-trusted Web PKI.

Jeremy