Ballot CSC-13 – Update to Subscriber Key Protection Requirements
Results of Review Period
(Mailing list post is available here.)
The review period has ended and no exclusion notices were filed.
The final documents, with the effective date being 2022-05-09, are available here.
Results of Voting
(Mailing list post is available here.)
| Yes | No | Abstain | |
|---|---|---|---|
| Certificate Issuers | Certum (Asseco), DigiCert, eMudhra, Entrust, HARICA, Sectigo, SSL.com | ||
| Certificate Consumers | Microsoft |
The ballot has PASSED.
Purpose of the Ballot
Update the subscriber private key protection requirements in the Baseline Requirement for the Issuance and Management of Publicly-Trusted Code Signing Certificates v2.7.
The following motion has been proposed by Ian McMillan of Microsoft and endorsed by Tim Hollebeek of DigiCert and Bruce Morton of Entrust.
Motion
This ballot updates the “Baseline Requirements for the Issuance and Management of Publicly‐Trusted Code Signing Certificates“ version 2.7 according to the attached redline which includes:
- Update section 16.3 “Subscriber Private Key Protection” to “Subscriber Private Key Protection and Verification”
- Update section 16.3 “Subscriber Private Key Protection” to include sub-sections “16.3.1 Subscriber Private Key Protection” and “16.3.2 Subscriber Private Key Verification”
- Update section 16.3 under new sub-section 16.3.1 to remove allowance of TPM key generation and software protected private key protection, and remove private key protection requirement differences between EV and non-EV Code Signing Certificates
- Update section 16.3 under new sub-section 16.3.1 to include the allowance of key generation and protection using a cloud-based key protection solution providing key generation and protection in a hardware crypto module that conforms to at least FIPS 140-2 Level 2 or Common Criteria EAL 4+
- Update section 16.3 under new sub-section 16.3.2 to include verification for Code Signing Certificates’ private key generation and storage in a crypto module that meets or exceeds the requirements of FIPS 140-2 level 2 or Common Criteria EAL 4+ by the CAs. Include additional acceptable methods for verification including cloud-based key generation and protection solutions and a stipulation for CAs to satisfy this verification requirement with additional means specified in their CPS. Any additional means specified by a CA in their CPS, must be proposed to the CA/Browser Forum for inclusion into the acceptable methods for section 16.3.2 by November 15, 2022.