[secdir] Secdir review of draft-ietf-trans-rfc6962-bis-39

[Charlie Kaufman <[e-mail]>]

I have reviewed this document as part of the security directorate's ongoing effort to review all IETF documents being processed by the IESG.  These comments were written primarily for the benefit of the security area directors.  Document editors and WG chairs should treat these comments just like any other last call comments.

I reviewed -31 two years ago, found no problems with it then, and examining the diffs find no problems with those either.

This is an interesting proposal for testing the validity of certificates in the Internet PKI (in addition to CRLs, OCSP, some DNS extension, and perhaps some others I'm forgetting), and it has functionality that overlaps with those. **PEOPLE INTERESTED IN TECHNICAL APPROACHES TO IMPROVING THE SECURITY OF THE INTERNET PKI SHOULD TAKE A LOOK AT THIS APPROACH WHETHER OR NOT THIS PARTICULAR PROPOSAL SUCCEEDS**.

It is a little odd that this is classed as experimental given that it appears to be deployed in Chrome and has enough history and evolution to be issuing a -bis.

The goal of this protocol is to prevent someone who captures the private key of a Certification Authority from issuing certificates for occasional use without the knowledge of the CA. It does this by registering all observed certificates in a log, encouraging clients to reject certificates not found in the log, and encouraging CAs to check the log for certificates signed with its key that were not signed through its authorized procedures.

The proposal specifies the actions of a partially trusted logging service that will take certificates as they are issued, sign an acknowledgement that can optionally be placed in the certificate itself or in the TLS headers during session initialization. The certificates are then placed in a Merkle hash tree and signed. This both reduces the signing work the log server has to do and allows it to prove that it has not removed any certificates from its database once they are posted there.

The protocol could be adapted for other logs that someone might want to audit for completeness and for following a policy of strictly-appending.

An interesting question that I did not see addressed in the I-D concerns whether the list of all issued certificates is made world-readable. The system assumes that the owners of particular domain names can watch for the issuance of bogus certificates for names they own, but many issuers do not want to make public the complete list of certificates they have issued for the same reason they would not want to release a complete list of DNS names they are using below their arc. DNS allows verification of guessed names but not enumeration of all names (at least optionally). Doing the same with this system would lose some of its security benefits, but not doing it would make it unacceptable to some issuers. This issue was discussed by the working group, but the security community might also want to comment.

	--Charlie