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CA/Forbidden or Problematic Practices

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== Potentially Problematic problematic CA Practices practices ==
This page contains draft comments about various CA practices that have been the subject of discussion in past CA evaluations. In general these practices are not explicitly addressed by the [http://www.mozilla.org/projects/security/certs/policy Mozilla CA certificate policy], and are we do not always necessarily consider them security risks. However we want to highlight them because they've occasioned controversy in the past and have in some cases caused approval of applications to be delayed. Some of these practices may be addressed in future versions of the policy.
=== Delegation Long-lived DV certificates === A domain-validated SSL certificate attests only to ownership and control of a domain name, and the owner of a domain name may have acquired it from others. It is therefore possible for the previous owner of the domain to have a still-valid DV certificate for the domain. If such a valid certificate (and associated private key) were to be used in conjunction with a DNS spoofing attack it would allow a malicious site to masquerade as a legitimate site and bypass the protection afforded by SSL. Some CAs issue DV SSL certificates that have expiration times several years in the future. This increases the time during which the possibility of such an attack exists. '''Important:''' According to section 6 of the [http://www.mozilla.org/projects/security/certs/policy/InclusionPolicy.html Mozilla CA Certificate Inclusion Policy] CAs who issue long-lived SSL certs must "verify that all of the information that is included in SSL certificates remains current and correct at time intervals of thirty-nine months or less" === Wildcard DV SSL certificates === Some CAs issue domain-validated SSL certificates that can function as wildcard certificates, e.g., a certificate for *.example.com where the CA verifies only ownership and control of the example.com domain, and the certificate subscriber can then use the certificate with any site foo.example.com, bar.example.com, etc. This means that a subscriber could establish malicious SSL-protected web site that are deliberately named in imitation of legitimate sites, e.g., paypal.example.com, without knowledge of the CA. Concerns have been expressed that wildcard SSL certificates should not be issued except to subscribers whose actual identity has been validated with organizational validation (OV). (There are no EV wildcard certificates.) === Email Address Prefixes for DV Certs ===* '''DRAFT''' Re-Write under discussion in mozilla.dev.security.policy [https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/inclusion/ Mozilla's CA Certificate Inclusion Policy] requires CAs to conform to the [[CA:BaselineRequirements|Baseline Requirements]] (BRs) in the issuance and management of publicly trusted SSL certificates. This includes the BR restrictions on the use of email as a way of validating that the certificate subscriber owns or controls the domain name to be included in the certificate. CAs are expected to conform to BR Section 11.1.1 (section 3.2.2.4 in BR version 1.3), which restricts the email addresses that may be used to authenticate the subscriber to information listed in the "registrant", "technical", or "administrative" WHOIS records and a selected whitelist of local addresses, which are limited to local-parts of "admin", "administrator", "webmaster", "hostmaster", and "postmaster". A CA that authorizes certificate subscribers by contacting any other email addresses is deemed to be non-compliant with Mozilla's CA Certificate Inclusion Policy and non-conforming to the Baseline Requirements, and may have action taken upon it as described in [https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/enforcement/ Mozilla's CA Certificate Enforcement Policy]. CAs are also reminded that Mozilla's CA Certificate Policy and the Baseline Requirements extend to any certificates that are technically capable of issuing SSL certificates, and subordinate CAs that fail to follow these requirements reflect upon the issuing CA that certified it. === Delegation of Domain / Email validation to third parties ===
Domain and Email validation are core-requirements of the [http://www.mozilla.org/projects/security/certs/policy/ Mozilla CA Policy] and should always be incorporated into the issuing CAs procedures whenever possible. Registration Authorities (RA) or other third parties performing such functions must provide attestations about their procedures and/or should be audited together with the issuing CA. The CA must demonstrate clear and efficient controls attesting the performance of its RAs. Delegation of domain/email validation to third parties should generally be avoided.
 
=== Issuing end entity certificates directly from roots ===
 
Some CAs issue end entity certificates directly from the root (i.e., signed using the root CA private key). This is not as secure as using an offline root and issuing certificates using a subordinate CA.
=== Allowing external entities to operate subordinate CAs ===
* The storage must be packaged in a way that the opening of the package causes irrecoverable physical damage. (e.g. a security seal)
* The PKCS#12 file must have a sufficiently secure password, and the password must not be transferred together with the storage.
 
=== Certificates referencing hostnames or private IP addresses ===
 
The standard model for SSL on the web assumes that an SSL certificate references a domain name that is resolvable using the public DNS infrastructure (e.g., "www.example.com") or an IP address that is reachable from the public Internet. However it is also possible to include in a certificate a hostname not resolvable through the public DNS (e.g., "home") or a private IP address (e.g., 192.168.1.101); for example, this might be done for a corporate intranet with SSL-enabled servers behind a firewall and employees who don't want to enter fully-qualified domain names.
 
We consider this a problematic practice for a public CA because a subscriber who obtains a certificate of this type could in theory use it in contexts other than the one for which the certificate was obtained, and in particular could use it to help enable an SSL MITM attack on users in other organizations who are using the same hostname or IP address for their own SSL-enabled servers. (Depending on the hostnames and private IP addresses used, this vulnerability might also affect users of home networks with SSL-enabled home gateway devices.)
 
[http://www.globalsign.com/resources/white-paper-internal-server-names-ip-address-requirements.pdf Guidance on the Deprecation of Internal Server Names and Reserved IP Addresses]
 
[http://www.cabforum.org/documents.html CA/Browser Forum Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates], BR 9.2.1 (section 7.1.4.2.1 in BR version 1.3): “As of the Effective Date of these Requirements, prior to the issuance of a Certificate with a subjectAlternativeName (SAN) extension or Subject Common Name field containing a Reserved IP Address or Internal Server Name, the CA shall notify the Applicant that the '''use of such Certificates has been deprecated by the CA / Browser Forum and that the practice will be eliminated by October 2016'''. Also as of the Effective Date, the CA shall not issue a certificate with an Expiry Date later than 1 November 2015 with a SAN or Subject Common Name field containing a Reserved IP Address or Internal Server Name. As from 1 October 2016, CAs shall revoke all unexpired Certificates.”
 
It is also a problematic practice to issue a certificate with non resolvable DNS or private IP and resolvable DNS adresses together.
 
It is not standards compliant for printable ASCII representations of IP addresses to be placed in any certificate field that is intended to hold DNS names, including the subject common name and the DNSName field of the Subject Alternative Names extension. There is a place in a certificate specifically intended to be where IP (v4 or v6) addresses may be placed. It is in the Subject Alternative Names extension. The SubjectAltNames extension has places for both additional DNS names and for IP addresses. The place for IP addresses takes them in binary form, not in printable ASCII (e.g. dotted decimal) form. See {{bug|553754}}.
 
=== Issuing SSL Certificates for Internal Domains ===
 
It has come to our attention that some Certification Authorities may have mistakenly issued SSL certificates to non-existent .int domain names. This appears to have happened because the .int domain may have been confused with internal domain names, and not all of the CAs and RAs may be aware that .int is an ICANN approved TLD.
 
Section 7 of Mozilla’s CA Certificate Policy states that CAs need to take “reasonable measures to verify that the entity submitting the certificate signing request has registered the domain(s) referenced in the certificate.” There are different interpretations as to what this means in regards to internal domain names such as non-valid TLDs, hostnames, and IP addresses. However, there is consensus that there are problems associated with issuing certificates for servers on internal networks under the same CA hierarchy as certificates for servers on public networks. Mozilla is currently discussing whether the CA Certificate Policy should be updated to add more explicit requirements on this practice, or even to disallow it altogether.
 
If you have issued certificates for internal domains within your CA hierarchy, Mozilla requests that you take the following actions:
# Perform an internal audit to look for certificates that have been issued within your CA hierarchy which have .int domain names in the Common Name and/or as DNS Names in the subjectAlternativeName. For each of these certificates, check to see if the certificate subscriber owns/controls that domain name, and revoke the certificate if they do not own/control that domain name.
# Review your controls/procedures (both internally and your RAs) for correct identification of internal and external domain names and verification that subscribers own/control the domain name to be included in their certificate. Please refer to these documents:
#* Section 7 of [http://www.mozilla.org/projects/security/certs/policy/ Mozilla’s CA Certificate Policy]
#* [[CA:Recommended_Practices|Recommended practices for CAs]]
 
Mozilla also recommends that you
# Implement automated checks to signal a red flag for domains such as .int and null characters in the Common Name and subjectAlternativeName of certificates.
# Maintain your own list of ICANN approved TLDs that are eligible to be used for domains in certificates issued within your CA hierarchy. If a new TLD is created by [http://www.icann.org/en/registries/top-level-domains.htm IANA], make an explicit decision whether or not to add the new TLD to your list.
=== OCSP Responses signed by a certificate under a different root ===
Please test your OCSP responder within the Firefox browser by enforcing OCSP as per our [[CA:Recommended_Practices#OCSP|CA Recommended Practices for OCSP.]]
 
=== SHA-1 Certificates ===
SHA-1 certificates may be compromised when attackers can create a fake cert that hashes to the same value as one with a legitimate signature, and is hence trusted. Mozilla can mitigate this potential vulnerability by turning off support for SHA-1 based signatures. The SHA-1 root certificates don’t necessarily need to be removed from NSS, because the signatures of root certificates are not validated (roots are self-signed). Disabling SHA-1 will impact intermediate and end entity certificates, where the signatures are validated.
 
There are still many end entity certificates that would be impacted if support for SHA-1 based signatures was turned off. Therefore, we are hoping to give CAs time to react, and are planning to turn off support for SHA-1 based signatures in 2017. Note that Mozilla will take this action earlier if needed to keep our users safe.
* CAs should not be issuing new SHA-1 certificates, and should be migrating their customers off of SHA-1 intermediate and end-entity certificates.
* If a CA still needs to issue SHA-1 certificates for compatibility reasons, then those SHA-1 certificates should expire before 2017.
* If you aren't sure whether or not your site is using SHA-1, please see https://shaaaaaaaaaaaaa.com/.
* [https://blog.mozilla.org/security/2014/09/23/phasing-out-certificates-with-sha-1-based-signature-algorithms/ Security Blog Post Regarding SHA-1 Based Signature Algorithms]
=== Generic names for CAs ===
'''Important:''' Both the O and the CN must be meaningful, and not generic terms such as "admin" or "root". It is not acceptable to have the O be a generic term such as "Admin" because it could mislead users that rely on the issuer details, such as when you hover your mouse over the domain or organization section in the address bar.
=== Lack of communication with end users Communication With End Users ===
CAs should be contactable by, and accept and act upon complaints made by, those relying on their assertions of identity. For CAs included in Mozilla, this will include being responsive to members of the general public, including people who have not purchased products from that CA.
=== Backdating the notBefore date ===
Certificates do not contain an issue timestamp, so it is not possible to be certain when they were issued. The notBefore date is the start of the certificate's validity range, and is set by the CA. It should be a reasonable reflection of the date on which the certificate was issued. Minor tweaking for technical compatibility reasons is accepted, but backdating certificates in order to avoid some deadline or code-enforced restriction is not.
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