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Ballot 221 – Two-Factor Authentication and Password Improvements

The voting period for Ballot 221 has ended and the ballot has failed.  Here are the results.

Voting by CAs – 6 votes total including abstentions

6 Yes votes: Amazon, DigiCert, HARICA, Kamu Sertifikasyon Merkezi, TWCA, TrustCor

0 No votes:

0 Abstain:

100% of voting CAs voted in favor

Voting by browsers – 1 vote total including abstentions

0 Yes votes:

1 No vote: Microsoft

0 Abstain:

100% of voting browsers voted in against

Under Bylaw 2.2(g), a ballot result will be considered valid only when more than half of the number of currently active Members has participated. Votes to abstain are counted in determining a quorum.  Half of currently active Members as of the start of voting is 9, so quorum was 10 votes – quorum was NOT met.

Bylaw 2.2(f) requires a yes vote by two-thirds of CA votes and 50%-plus-one browser votes for approval.  Votes to abstain are not counted for this purpose.  This requirement was met for CAs but was NOT met for browsers.

At least one CA Member and one browser Member must vote in favor of a ballot for the ballot to be adopted.  This requirement was NOT met.

The ballot fails.

Purpose of Ballot: The Network Security Working Group met a number of times to improve the Network Security Guidelines requirements around authentication, specifically by requiring two-factor authentication, and improving the password requirements in line with more recent NIST guidelines.

While CAs are encouraged to improve their password requirements as soon as possible, a two year grace period is being given to allow organizations to develop and implement policies to implement the improved requirements, especially since some organizations may have to simultaneously comply with other compliance frameworks that have not been updated yet and are based on older NIST guidance about passwords.

The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.


This ballot modifies the “Network and Certificate System Security Requirements” as follows, based upon Version 1.1:

In the definitions, add a definition for Multi-Factor Authentication:

“Multi-Factor Authentication: An authentication mechanism consisting of two or more of the following independent categories of credentials (i.e. factors) to verify the user’s identity for a login or other transaction: something you know (knowledge factor), something you have (possession factor), and something you are (inherence factor).  Each factor must be independent.  Certificate-based authentication can be used as part of Multifactor Authentication only if the private key is stored in a Secure Key Storage Device.”

Capitalize all instances of the defined term “Multi-Factor Authentication”.

Add a definition for Secure Key Storage Device:

“Secure Key Storage Device: A device certified as meeting at least FIPS 140-2 level 2 overall, level 3 physical, or Common Criteria (EAL 4+).”

In section 1.j., capitalize Multi-Factor Authentication, and strike the parenthetical reference to subsection 2.n.(ii).

In section 2.f., add “(for accountability purposes, group accounts or shared role credentials SHALL NOT be used)” after “authenticate to Certificate Systems”.

Change section 2.g. to read:

“g. If an authentication control used by a Trusted Role is a username and password, then, where technically feasible, implement the following controls:

  1. For accounts that are accessible only within Secure Zones or High Security Zones, require that passwords have at least twelve (12) characters;
  2. For authentications which cross a zone boundary into a Secure Zone or High Security Zone, require Multi-Factor Authentication.  For accounts accessible from outside a Secure Zone or High Security Zone require passwords that have at least eight (8) characters and are not be one of the user’s previous four (4) passwords; and implement account lockout for failed access attempts in accordance with subsection k;
  3. When developing password policies, CAs SHOULD take into account the password guidance in NIST 800-63B Appendix A.
  4. If passwords are required to be changed periodically, that period SHOULD be at least two years.  Effective April 1, 2020, if passwords are required to be changed periodically, that period SHALL be at least two years.”

In section 2.h., change “Require” to “Have a policy that requires”

In section 2.i., change “Configure” to “Have a procedure to configure”

Change section 2.k. to read:

“k. Lockout account access to Certificate Systems after no more than five (5) failed access attempts, provided that this security measure:

  1. is supported by the Certificate System,
  2. Cannot be leveraged for a denial of service attack, and
  3. does not weaken the security of this authentication control;”

Change section 2.n. to read:

“Enforce Multi-Factor Authentication for all Trusted Role accounts on Certificate Systems (including those approving the issuance of a Certificate, which equally applies to Delegated Third Parties) that are accessible from outside a Secure Zone or High Security Zone; and”


The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: 2018-03-28  15:00:00 EDT

End Time: 2018-05-17 17:45:00 EDT

Vote for approval (7 days)

Start Time: 2018-05-17 17:45:00 EDT

End Time: 2018-05-24 17:45:00 EDT