2023-10-19 Minutes of the Code Signing Certificate Working Group

Table of Contents

Attendees

  • Aaron Poulsen – Amazon Trust Services
  • Andrea Holland – VikingCloud
  • Atsushi INABA – GlobalSign
  • Bruce Morton – Entrust
  • Corey Bonnell
  • Dean Coclin-DigiCert
  • Dimitris Zacharopoulos (HARICA)
  • Ian McMillan – Microsoft
  • Janet Hines – VikingCloud
  • Richard Kisley – IBM
  • Mohit Kumar – GlobalSign
  • Rollin Yu – TrustAsia
  • Scott Rea – eMudhra
  • Tim Crawford – BDO/WebTrust

Minutes

  • Assign Minute taker (start recording)
    • Ian McMillan
  • Roll call
    • Completed by Dean
  • Antitrust Compliance Statement
    • Completed by Dean
  • Review Agenda
    • No comments on the agenda
  • Approval of prior meeting minutes – F2F 5 Oct, Need minutes!
    • Minutes received from Mohit
    • Need to get other half of the minutes from Tim Callan (Dean to follow up)
  • Ballot CSC-20 Restore Version Reference to EV Guidelines
    • Voting completed and it has passed with quorum
  • Ballot CSC-21 Signing Service
    • In discussion period
    • Comments on the definition of Signing Service
      • This definition must not apply to a subscriber and that includes when the CA is a subscriber itself.
      • Current definition seems to not be clear for CAs that leverage a Signing Service they provide and how the Subscriber Agreement would apply or not in this case.
        • Microsoft has a case where the Signing Service does a Subscriber Agreement with the CA service team with a separation of duties between the teams, so there is precedence for this behavior.
      • Signing Service does not include a subscriber’s managed signing service.
      • New proposed definition: An organization that generates the key pair and securely manages the private key associated with the code signing certificate on behalf of the subscriber.
    • Audit Requirements and Audit Dates
      • We should consider an effective date to allow for Signing Services to comply with the requirements
        • There should a ramp up period or include it in the next audit period so not to include it current audit periods.
        • We need to give CAs runway to get this into their audit plans
        • We should provide an effective date of 6 months from the projected ballot completion timeframe (e.g. June 1, 2024) for the audits starting after that effective date.
      • Section 8.4 currently requires a Signing Service to comply with the audit requirements for a CA or a Delegated 3rd Party
        • Is it possible that CSBRs say Signing Services must comply with the requirements including audits for the NetSec BRs, but they are not?
        • How does a CA know there is a Signing Service or not?
          • Resellers come into the picture here
          • Previously we questioned if Signing Services should have these audit requirements and we talked ourselves into it.
          • We can lean on the Subscriber Agreement and Subscriber Warranties to push the audit requirements onto 3rd party Signing Services and Resellers
        • How are these enforced?
          • 3 scenarios here…
            • CA that provides a Signing Service to Subscribers
              • Assumption is these are already being audited
            • CA that partners with a 3rd Party Signing Service to the CA subscribers
            • Subscriber uses a unaffiliated 3rd Party Signing Service to use a CA issued code signing certificate (CA may or may not be aware there is a signing service in the loop unless the Subscriber notifies the CA)
              • More or less a private key protection service
              • This is not easy here to tell when 3rd party Signing Service is involved
          • First focus on Signing Services that CAs know about, but this will not be equivalent
            • CAs with a Signing Service has the hardest compliance challenge, but a unaffiliated 3rd party Signing Service (Reseller) would not have the same requirements
            • We should consider dropping these audit requirements on the Signing Services and focus on the subscriber private key protection requirements
              • The one point we are considering is the Signing Service risk with a multi-tenant service, this is the same as Resellers.
              • Can we look at prohibiting Resellers from having an unaudited Signing Service?
            • We made a lot of progress here so we should consider moving forward as-is
      • Consider using the S/MIME BR language for effective date, Bruce/Corey to review that language
  • Proposed Ballot High Risk
    • No updates until CSC-21 is completed
  • Proposed ballot Remove EV Guideline References
    • Will pick this up once we have all the notes from the F2F discussion
  • Proposed ballot CSCWG Charter Update
    • Need Martijn to update here
  • Other business
    • None
  • Next meeting – 2 November

Check Also

Minutes of the F2F 60 Meeting in Portsmouth, NH, USA, 3-5 October 2023 – SCWG (4 October)

Server Cert Working Group Date: October 4, 2023 Minute Taker: Kiran Tummala (Microsoft)     …