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2021-11-18 Minutes of the Code Signing Certificate Working Group


Andrea Holland, Atsushi Inaba, Bruce Morton, Chris Kemmerer, Correy Bonnell, Dimitris Zacharopoulos, Ian McMillan, Inigo Barreira, Kiran Tummala, Sebastian Schulz, Tim Hollebeek


Minutes of the previous Meeting were approved

Discussion regarding SC-50 from Server Working Group

– Ballot is concerned with removal of 4.1.1

– Discussion is postponed until any changes are required

Ballot CSC-12

– Ballot has passed, in IPR review through 3rd December

Ballot CSC-6

– Effective date is set to Sep 1st 2022 based on reccuring feedback from the group

– Date seems reasonable for most CAs but some want to double check time needed to implement

– Discussion of proposed changes to 16.3.1:

– Dimitris points out that the CA shipping crypto modules with keys should explicitly be allowed to ship modules with multiple keys

– Dimitris also points out that the current language would allow the CA to import keys to the crypto module

– Hence, the CA should be required to generate a key inside the crypto module

– Sebastian mentions that since it is already required for the subscriber to generate keys on the module, it should follow for CAs to do the same

– Overall, there is agreement that it would make sense to add that requirement explicitly

– Language on the ballot is being updated slightly, as per Dimitris proposal over Email

– Ian proceeds to discuss the requirements around generating the key on a suitable hardware crypto module, with a CSR signed by the manufacturer to claim generation of the key on the hardware

– Discussing whether or not that phrasing might be redundant, Tim points out that an auditor would still be able to distinguish

– Upon a question for the difference between items 2 and 3, Dimitris points out that 2 is Remote Key Attestation while 3 is constrained by enrolment with a cetain crypto library

– Regarding item 4, Ian mentions that Microsoft provides verification by IT audit for their own CodeSigning

– Tim Hollebeek mentions that there are some others using this method

– Dimitris has concerns that the language may be misinterpreted by some to provide their own audit (non-FIPS) for the devices

– Tim mentions that some use non-standard security practices that in assurance level exceed what is required by the BR

– Bruce points out that an audit should ideally show only that a suitable device according to BR is used, not introduce evluation of a new device

– Dimitris still encourages reqording of the paragraph, to clarify

– Tim points at that “suitable” needs a more clear-cut definition of what is acceptable, are internal IT audits acceptable?

– For Ian, any audit that would clarify make, model and procedures would be sufficient but that didnt come through for the whole group

– Dimitris is also pointing at item 6, which specifies CA or qualified auditor witnessing key creation. Does this overlap with item 4?

– Through discussion, it becomes clear that number 4 and 6 are meant for different purposes (bigger and smaller customers respectively)

– Tim points out that specifying IT audits would complicate this ballot and can be improved upon in the future

– Dimitris points out item number 8, and how approval might conflict with items 1 to 7

– It’s generally agreed that item number 8 is only meant to cover methods that are not described by item 1 through 7

– Regarding item number 8, CAs should also bring up additional methods to . This seems mostly important to CAs not participating (of whicht here are many)

– Looping back to item number 4, Dimitris is asking for clarification whether an itnernal or external audit should be used

– There is discussion around whether and what should be clarified now and what should be addressed with a future ballot

– Dimitris will propose some language for clarification of item 4

– Bruce also raises some concerns regarding reuse, specifically for item 4 and 5 (limiting the validity of audits or reports)

– Bruce is pointing out that reuse is already addressed in section 11 (validation)

– Dimitris is mentioning that there are different reuse periods for EV and non-EV

– Ian believes that the reuse period of EV (13 months) is more appropiate, Bruce will update the ballot for items 4, 5 and 7

– Corey is mentioning that 11.7 also has some specifications regarding takeover attacks and wondering whether these should be updated as well

– Dimitris agrees that it should be updated with the ballot, Ian agrees to update

Discussion regarding CSBR format change

– Corey has been distributing an updated mapping document and incorporated CSC-11 changes

– Dimitris agrees that most mapping seems ok so far, with only some comments remaining

– Dimitris comes with a reminder that clarification ballots should not introduce normative changes

– The appendix with certificate profile sections talks about Email Protections EKUs being allowed – should this be added to 3647 conversion?

– Corey refers to MS Root program requirements for Email protection and Document Signing EKUs

– Bruce suggests that while not updating with the conversion, but introducing a new ballot immediately to make the changes. The group agrees

– Corey is addressing the delegation of audits as well, with Dimitris agreeing that the section needs further discussion (section 14.2.1)

– For Dimitris, it reads as if delegated RA can be internall audited

– Overall, it doesn’t seem like it’s a format change issue but there’s a problem with the existing content not being understood properly

– If it’s not understood, should it not be moved or moved just somewhere because some may rely on it?

– There’s agreement that the item needs further discussion and updating before introduing a format change

Next Meeting is December 2nd, Meeting is adjourned

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