On Dec 26, 5:38 pm, Nelson B Bolyard <nel...@bolyard.me> wrote:

> Clearly several participants in this discussion were surprised that a CA would
> delegate the duty of validating domain control to an RA, and some opined
> that a CA ought to perform that duty itself.

I certainly fall in that category.

> I'm not convinced that's necessary, but it certainly does seem that a CA firm
> ought to be prepared to deal with the possibility that an RA makes a 
> (potentially
> big) mistake without sacrificing the CA firm's entire business. The 
> challenge, in
> the event of an RA error, is to restore/maintain confidence in the integrity
> of the CA's PKI overall, while mitigating the potential damage from dubious
> enrollments.

I think I can boil down my concern in this statement:

When trust is being established in a certification authority, trust is
explicitly being placed in its operational practices. It is not being
trusted in its ability to place trust in turn in whomever it may
decide to outsource its operations. By allowing arbitrary parties to
perform critical RA activities (such as DV) the CA is attempting to
extend its operations beyond that which was originally judged.

> So, I would like to suggest that Comodo consider modifying its practices
> somewhat, to reduce the mismatch of scope between subordinate CAs and RAs.
> I suggest that Comodo operate a separate subordinate CA for each RA to
> whom Comodo has delegated validation duties.  I suggest that a new
> subordinate CA be created for each such RA, and that all new certs issued
> for those RAs be issued from those new single-RA CAs.  I am aware of at
> least one other commercial CA that operates that way, operating a separate
> subordinate CA for each RA to whom they have delegated validation duties.
> I believe that is a sound way to minimize the "collateral damage" that
> might need to be inflicted, even temporarily, to restore/maintain PKI
> integrity in the event of a breach.

I believe your suggestion is valid. This seems to fit s. 13 of the
Mozilla CA Certificate policy: "... we recommend that CAs consider
using separate root CA certificates with separate public keys (or
separate intermediate CA certificates with separate public keys under
a single root) when issuing certificates according to different
Certificate Policies, so that we or others may selectively enable or
disable acceptance of certificates issued according to a particular
policy, or may otherwise treat such certificates differently ..."

I believe another valid option would be for the CA to incorporate key
RA duties, namely domain verification. The CA can still have resellers
that initiate registration and collect information. Verification would
remain within the operations of that which is judged in the CA's
conformance to policy.
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