477028 - Add Buypass AS root certificates

Status: RESOLVED FIXED

(CA Program :: CA Certificate Root Program, task)

Description

[John Arild A. Johansen]

User-Agent:       Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; GTB5; InfoPath.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; MS-RTC LM 8; .NET CLR 3.0.04506.648; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729)
Build Identifier: N/A

Buypass AS recently passed the Webtrust for CA and EV SSL audit and we are now ready to progress with getting our two root certificates included in the various browsers. 

According to the submission process described on your website (http://www.mozilla.org/projects/security/certs/policy/) we are hereby submitting the following information:

We would like to submit 2 -two- roots:

1. Buypass Class 2 CA 1
----BEGIN CERTIFICATE-----
MIIDUzCCAjugAwIBAgIBATANBgkqhkiG9w0BAQUFADBLMQswCQYDVQQGEwJOTzEd
MBsGA1UECgwUQnV5cGFzcyBBUy05ODMxNjMzMjcxHTAbBgNVBAMMFEJ1eXBhc3Mg
Q2xhc3MgMiBDQSAxMB4XDTA2MTAxMzEwMjUwOVoXDTE2MTAxMzEwMjUwOVowSzEL
MAkGA1UEBhMCTk8xHTAbBgNVBAoMFEJ1eXBhc3MgQVMtOTgzMTYzMzI3MR0wGwYD
VQQDDBRCdXlwYXNzIENsYXNzIDIgQ0EgMTCCASIwDQYJKoZIhvcNAQEBBQADggEP
ADCCAQoCggEBAIs8B0XY9t/mx8q6jUPFR42wWsE425KEHK8T1A9vNkYgxC7McXA0
ojTTNy7Y3Tp3L8DrKehc0rWpkTSHIln+zNvnma+WwajHQN2lFYxuyHyXA8vmIPLX
l18xoS830r7uvqmtqEyeIWZDO6i88wmjONVZJMHCR3axiFyCO7srpgTXjAePzdVB
HfCuuCkslFJgNJQ72uA40Z0zPhX0kzLFANq1KWYOOngPIVJfAuWSeyXTkh4vFZ2B
5J2O6O+JzhRMVB0cgRJNcKi+EAUXfh/RuFdV7c27UsKwHnjCTTZoy1YmwVLBvXb3
WNVyfh9EdrsAiR0WnVE1703CVu9r4Iw7DekCAwEAAaNCMEAwDwYDVR0TAQH/BAUw
AwEB/zAdBgNVHQ4EFgQUP42aWYv8e3uco684sDntkHGA1sgwDgYDVR0PAQH/BAQD
AgEGMA0GCSqGSIb3DQEBBQUAA4IBAQAVGn4TirnoB6NLJzKyQJHyIdFkhb5jatLP
gcIV1Xp+DCmsNx4cfHZSldq1fyOhKXdlyTKdqC5Wq2B2zha0jX94wNWZUYN/Xtm+
DKhQ7SLHrQVMdvvt7h5HZPb3J31cKA9FxVxiXqaakZG3Uxcu3K1gnZZkOb1naLKu
BctN518fV4bVIJwo+28TOPX2EZL2fZleHwzoq0QkKXJAPTZSr4xYkHPB7GEseaHs
h7U/2k3ZIQAw3pDaDtMaSKk+hQsUi4y8QZ5q9w5wwDX3OaJdZtB7WZ+oRxKaJyOk
LY4ng5IgodcVf/EuGO70SH8vf/GhGLWhC5SgYiAynB321O+/TIho
-----END CERTIFICATE-----

a0 a1 ab 90 c9 fc 84 7b 3b 12 61 e8 97 7d 5f d3 22 61 d3 cc (Class 2)

Friendly Name: Buypass Class 2 CA 1

EKUs:
Server Authentication
Client Authentication
Secure E-mail
Time stamping
--------------

2. Buypass Class 3 CA 1
-----BEGIN CERTIFICATE-----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-----END CERTIFICATE-----

61 57 3a 11 df 0e d8 7e d5 92 65 22 ea d0 56 d7 44 b3 23 71 (Class 3)

Friendly Name: Buypass Class 3 CA 1

EKUs
Server Authentication
Client Authentication
Secure E-mail
Time stamping

EV OID:
2.16.578.1.26.1.3.3
--------------------------
o for each CA certificate requested for inclusion, whether or not the CA issues certificates for each of the following purposes within the CA hierarchy associated with the CA certificate: 
• SSL-enabled servers,
• digitally-signed and/or encrypted email, or • digitally-signed executable code objects; 

[Buypass]Both CA certificates issues certificates for SSL-enabled servers and digitally signed or entrypted email. None of them issues certificates for signing executable code objects.

o for each CA certificate requested for inclusion, whether the CA issues Extended Validation certificates within the CA hierarchy associated with the CA certificate and, if so, the EV policy OID associated with the CA certificate; 

[Buypass] Described above under the "Class 3" certificate description. Buypass Class 3 CA 1 issues EV certificates using EV OID as defined above Buypass Class 2 CA 1 do not issue EV certificates

o a Certificate Policy and Certification Practice Statement (or links to a CP and CPS) or equivalent disclosure document(s) for the CA or CAs in question; and o information as to how the CA has fulfilled the requirements stated above regarding its verification of certificate signing requests and its conformance to a set of acceptable operational criteria.

[Buypass]
CP and CPS: http://www.buypass.no/Bedrift/Produkter+og+tjenester/SSL/SSL%20dokumentasjon

[Buypass]
Buypass and our CA practise has undergone the following third-party audits:

1) Webtrust for CA and EV SSL (readiness). Link to the Webseal: https://cert.webtrust.org/ViewSeal?id=848

2) ISO/IEC 27001:2005 compliance

3) Payment Cars Industry (PCI-DSS) compliance

4) ...and it's worth mentioning that mostly EAL 4+, ITSEC E6 and FIPS certified technology in use 



Reproducible: Always




The Buypass Class 3 certificates are either issued to persons or enterprises. The certificates may be used for authentication purposes, encryption/decryption and/or electronic signatures (non-repudiation). The certificates are part of an infrastructure provided by Buypass AS enabling electronic commerce in Norway. The certificates are used by many different service providers ranging from purely commercial companies to governmental and other public institutions including the health sector. 

Buypass Class 2 certificates are issued to persons or enterprises and have the same basic usage areas as Class 3 certificates. The Class 2 CP has, however, less strict requirements with respect to identification of the requesting party and thus have a somewhat lower quality than Class 3 certificates. 

We are currently ready to include SSL certificates, including EV, in our certificate portfolio as well. Extended Validation SSL certificates will be issued exclusively by Class 3 CA. 


Contacts from our organization:
o John Arild Johansen (CSO), [e-mail] , [phone] (cell) / [phone] (office)   
o Anne-Grethe Eilertsen (Project Manager), [e-mail] , [phone] (cell) / [phone] (office)

Company name and address information 

o Buypass AS, Nydalsveien 30A, P.O. Box 4364 Nydalen, N-0402 Oslo 
o Oganization no.: NO 983 163 327 MVA

Company Web page address: www.buypass.no

Please let me know if anything’s missing.
We are looking forward the work closer with you on this important area!


Best regards,

John Arild A. Johansen  •  CSO/Sikkerhetssjef  •  Buypass AS

Comment 1

[John Arild A. Johansen]

(The request also applies for SeaMonkey, Camino and Thunderbird...all products/projects were root certificates are needed for optimizing the user experience.)

Comment 2

[John Arild A. Johansen]

Attachment: Buypass CA certs

The actual certs.

Comment 3

[John Arild A. Johansen]

Attachment: Buypass CA test-certs

Test certificates

Comment 4

[Kathleen Wilson]

Accepting this bug so we can begin the Information Gathering and Verification
phase as described in https://wiki.mozilla.org/CA:How_to_apply.

Comment 5

[Kathleen Wilson]

Attachment: Initial Information Gathering Document

Attached is the initial information gathering document which summarizes the information that has been gathered and verified. Please review the document for accuracy and completeness.  Within the document the items highlighted in yellow indicate where further clarification is needed. I will also summarize here.

1) Please provide a CA hierarchy description and/or diagram for each root.

a) Are there internally operated subordinate CAs chaining up to these roots? For internally-operated subordinate CAs the key is to confirm that their operation is addressed by the relevant CP/CPS, and that any audit covers them as well as the root.

b) If there are subordinate CAs that are operated by third parties, please provide a general description and explain how the CP/CPS and audits ensure the third parties are in compliance.
If applicable, please see
https://wiki.mozilla.org/CA:SubordinateCA_checklist
Are any of the sub-CAs that are operated by third-parties are or will be EV enabled? If the answer is yes, then please refer to 
http://www.cabforum.org/EV_Certificate_Guidelines_V11.pdf
section 7.b.1 and section 37b.

c) Have either of these roots been involved in cross-signing with another root?

2) Please review the potentially problematic practices list at http://wiki.mozilla.org/CA:Problematic_Practices. 
For relevant items, provide further information.

3) Please provide the url to the WebTrust EV audit report and management assertions document.

4) I haven’t found email verification information yet. Perhaps this is in the CP/CPS for “Buypass Class 3 Enterprise Certificates”, which I don’t think I have the url for?
This is in regards to section 7b of http://www.mozilla.org/projects/security/certs/policy/
b)for a certificate to be used for digitally signing and/or encrypting email messages, the CA takes reasonable measures to verify that the entity submitting the request controls the email account associated with the email address referenced in the certificate or has been authorized by the email account holder to act on the account holder's behalf;

Comment 6

[John Arild A. Johansen]

Attachment: WebTrust EV SSL Independent Auditors Report and mgmt Assertion

Ref. 3)

Comment 7

[John Arild A. Johansen]

Here's the Buypass response to the additional questions:
 
1) Only a single root CA exist and there is no subordinate CA. This root has not been involved in cross-signing with another root (goes for both class 2 & 3)

2) We’ve have reviewed the list and found two relevant items for our CA operation and/or practise:
a) Issuing end entity certificates directly from roots:
The roots are the only Buypass CAs that issues certificates to end entities. This is a very simple, however sufficient model for Buypass (so far).

b) Distributing private keys in PKCS#12 files:
This is done only for Enterprise certificates, all SSL certificates are issued on keys generated by the subscriber. 

3) Has been uploaded to this bug as an PDF attachment. 

4) Subject email-address was an option for Enterprise certificates previously, no longer used.

Comment 8

[Kathleen Wilson]

The roots under discussion are:
Buypass Class 2 CA 1 (valid 2006 to 2016)
Buypass Class 3 CA 1 (valid 2005 to 2015), also requesting EV-enablement

>> Both roots issue end-entity certificates directly. 

This may be a show-stopper. 

The practice of issuing end-entity certificates directly from roots is highly discouraged, and may result in delay and/or denial of the request to include these certificates, and in particular the EV-enablement request for the Class 3 root.

I realize that issuing sub-CAs and getting them through audits can be time-consuming and expensive, especially since you just completed your WebTrust CA/EV audits in December.

We could move forward with this request and see what happens, but it is possible that the end result will be that sub-CAs are required before inclusion into Mozilla and EV-enablement will be approved. Then this would only have delayed your progress by several months.

Would someone who is more knowledgeable about this issue than I am, please provide some input on how to proceed with this request?

Thanks,
Kathleen

Comment 9

[Frank Hecker]

(In reply to comment #8)
> The roots under discussion are:
> Buypass Class 2 CA 1 (valid 2006 to 2016)
> Buypass Class 3 CA 1 (valid 2005 to 2015), also requesting EV-enablement
> 
> >> Both roots issue end-entity certificates directly. 
> 
> This may be a show-stopper. 

My comments below.

> The practice of issuing end-entity certificates directly from roots is highly
> discouraged, and may result in delay and/or denial of the request to include
> these certificates, and in particular the EV-enablement request for the Class 3
> root.

My position on this is as follows: As noted in our problematic practices document, we do think that issuing end-entity certificates directly from a root is not a good practice, and that a better practice would be to issue EE certificates from a subordinate CA that can act as the issuing CA. However there is nothing in our current CA policy that prohibits issuing EE certificates directly from a root. I've also looked through the EV guidelines, and I can't see anything there that prohibits issuing EE certificates directly from the root.

So: I urge Buypass to consider establishing a subordinate CA to issue EV certificates, instead of continuing to issue them directly from the root, and to operate the root in an off-line mode (where it will issue only subordinate CA certificates). However I don't see a justification for delaying its request until this change is made.




> I realize that issuing sub-CAs and getting them through audits can be
> time-consuming and expensive, especially since you just completed your WebTrust
> CA/EV audits in December.
> 
> We could move forward with this request and see what happens, but it is
> possible that the end result will be that sub-CAs are required before inclusion
> into Mozilla and EV-enablement will be approved. Then this would only have
> delayed your progress by several months.
> 
> Would someone who is more knowledgeable about this issue than I am, please
> provide some input on how to proceed with this request?
> 
> Thanks,
> Kathleen

Comment 10

[Kathleen Wilson]

Frank, thank you for the clarification.

John, Here’s my remaining questions.

In regards to Comment #7: Subject email-address was an option for Enterprise certificates previously, no longer used.
Does this mean that only the Websites (SSL/TLS) trust bit should be enabled for both roots?  And the Email (S/MIME) trust bit should not be enabled?  

For testing purposes, for each root please provide a url to a web site whose certificate chains up to the root. For the Class 3 root, please have the website cert be EV.

In regards to the WebTrust EV audit attached to bug in Comment #6, 7
When audit reports are provided by the company requesting CA inclusion rather than having an audit report posted on the website such as cert.webtrust.org, the Mozilla process requires doing an independent verification of the authenticity of audit reports that have been provided.
Please send me the KPMG email address(es) of the auditors.

Thanks,
Kathleen

Comment 11

[John Arild A. Johansen]

First of all, thanks for the progress and follow-up on this.  :-D

1) Issuing directly from root:
Buypass established the CA activity in 2005 (Buypass Class 3 CA 1) and the focus was issuance of certificates in the Norwegian market. One of the main design principles was simplicity and as a new actor in a immature Norwegian certificate market the simple, yet sufficient solution with one single CA was a natural choice. We established the Buypass Class 2 CA 1 in 2006 in order to add some more flexibility to our certificate product range. 

We fully understand the advantages of having a CA hierarchy and our current strategy is to revise our CA structure when we are to replace the Buypass Class 3 CA 1, no later then 2012. During this revision of our CA structure, a CA hierarchy with one or more offline root CAs and separate issuing CAs will most probably be the preferred choice. 

Furthermore, we had a discussion on the topic with our auditors before starting the WebTrust engagement and learned that the EV Guidelines does not require certificates being issued from a subordinate issuing CA under a Root. 

Buypass has taken adequate measures to secure the private key of the issuing CA (being also the root).

2) Subject email-address:
The Email (S/MIME) trust bit should not be enabled.

3) Web sites for testing purposes:
https://evident.ssl.buypass.no/ssl/evident/
https://domain.ssl.buypass.no/ssl/domain/
https://business.ssl.buypass.no/ssl/business/

4) KMPG auditor contact information:

Mr. P.H. (Patrick) Paling RE
Senior Manager, IT Advisory
ICT Security & Control, Identity & Access Management

KPMG Advisory N.V.
Trade register number: 33263682

P.O. Box 74105
1070BC  AMSTERDAM
THE NETHERLANDS

Tel	[phone]
Secr	[phone]
Fax	[phone]
Mobile	[phone]

[e-mail]

Thanks, 
John A.

Comment 12

[Kathleen Wilson]

Attachment: Completed Information Gathering Document

Comment 13

[Kathleen Wilson]

This completes the information gathering and verification phase of this
request.

This request will be scheduled for public discussion as per
https://wiki.mozilla.org/CA:Schedule

Information will be posted here when the public discussion begins.

Comment 14

[Kathleen Wilson]

I am now opening the first public discussion period for this request from Buypass to add the Buypass Class 2 CA 1 and Buypass Class 3 CA 1 root certificates to NSS, enabling only the Websites trust bit for both roots. This request is also to enable the Buypass Class 3 CA 1 root certificate for EV.

For a description of the public discussion phase, see https://wiki.mozilla.org/CA:How_to_apply#Public_discussion

Public discussion will be in the mozilla.dev.security.policy newsgroup and the corresponding [e-mail] mailing list.

http://www.mozilla.org/community/developer-forums.html
https://lists.mozilla.org/listinfo/dev-security-policy
news://news.mozilla.org/mozilla.dev.security.policy

The discussion thread is called “Buypass Root Inclusion Request”

Please actively review, respond, and contribute to the discussion.

Comment 15

[Kathleen Wilson]

The public comment period for this request is now over. 

This request has been evaluated as per sections 1, 5 and 15 of the official CA policy at

 http://www.mozilla.org/projects/security/certs/policy/

Here follows a summary of the assessment. If anyone sees any factual errors, please point them out.

To summarize, this assessment is for Buypass’s request to add the Buypass Class 2 CA 1 and Buypass Class 3 CA 1 root certificates to NSS, enabling the Websites trust bit for both roots. This request is also to enable the Buypass Class 3 CA 1 root certificate for EV. 

Section 4 [Technical]. I am not aware of any technical issues with certificates issued by Buypass, or of instances where they have knowingly issued certificates for fraudulent use. If anyone knows of any such issues or instances, please note them in this bug report.

Section 6 [Relevancy and Policy]. Buypass appears to provide a service relevant to Mozilla users: It is a public corporation in Norway.

The certificate policies for Buypass are published on their website and listed in the entries on the pending applications list. The main documents are the Class 2 and Class 3 SSL Certificate Policies and Certificate Practice Statements. All four documents are provided in English.

Class 2 SSL CP: http://www.buypass.no/_binary?download=true&id=1270
Class 2 SSL CPS: http://www.buypass.no/_binary?download=true&id=1272
Class 3 SSL CP: http://www.buypass.no/_binary?download=true&id=1271
Class 3 SSL CPS: http://www.buypass.no/_binary?download=true&id=1273

* EV Policy OID 2.16.578.1.26.1.3.3

Section 7 [Validation]. Buypass appears to meet the minimum requirements for subscriber verification, as follows:

* Email: Not Applicable.

* SSL: Section 4.1.1 of both the Class 2 SSL CP and the Class 3 SSL CP state that it must be verified that the Subscriber is a registered holder or has control of the domain name to be included in the SSL Certificate. Additionally, in the Class 3 SSL CP the verification procedures include conforming to the information verification requirements defined by the CA/Browser Forum Guidelines for EV.

* Code: Not Applicable.

Section 8-10 [Audit]. Section 8-10 [Audit].  Both the WebTrust CA and the WebTrust EV Readiness audits were recently performed by KPMG. The WebTrust CA audit, which is posted on cert.webtrust.org, covers both the Class 2 and the Class 3 SSL Certificates issued by these roots.  The WebTrust EV Readiness Audit is for the Class 3 root, and is attached to the bug. I have exchanged email with KPMG to confirm the authenticity of this audit. 

Section 13 [Certificate Hierarchy].  The Buypass Class 2 CA 1 and Buypass Class 3 CA 1 root certificates do not have intermediate CAs; both roots issue end-entity certificates directly. Buypass plans to introduce new roots with intermediate CAs, expecting the planning and roll-over process to be done by May 2012. Inclusion of the current roots is requested in order to support the current customers until the roll-over process is completed. 

Other: 
* Both CRL and OCSP are provided.
** Next update for CRLs of end-entity certs is 24 hours.
** Class 3 SSL CP section 4.4.11: The OCSP service SHALL be updated at least every 24 hours, and OCSP responses from this service SHALL have a maximum expiration time of 48 hours.

Potentially problematic practices: One potentially problematic practice was noted, which is that the roots issue end-entity certificates directly. This has been thoroughly reviewed and discussed. There is nothing in the current CA policy that prohibits issuing end-entity certificates directly from a root. Additionally, in the EV guidelines there doesn’t appear to be anything that prohibits issuing end-entity certificates directly from the root.

Based on this assessment I recommend that Mozilla approve the request to add the Buypass Class 2 CA 1 and Buypass Class 3 CA 1 root certificates to NSS, enabling the Websites trust bit for both roots, and enabling EV for the Buypass Class 3 CA 1 root certificate.

Comment 16

[Frank Hecker]

To Kathleen: As always, thank you for your work on this request.

To the representatives of Buypass AS: Thank you for your cooperation and your patience.

To all others who have commented on this bug or participated in the public discussion: Thank you for volunteering your time to assist in reviewing this CA request.

I have reviewed the summary and recommendation in comment #15, and on behalf of the Mozilla project I approve this request from Buypass AS to include the following root certificates in Mozilla, with trust bits set as indicated:

* Buypass Class 2 CA 1 (SSL)
* Buypass Class 3 CA 1 (SSL)

I also approve the request to enable the following root certificate for EV use, with EV policy OID as indicated:

* Buypass Class 3 CA 1 (2.16.578.1.26.1.3.3)

Kathleen, could you please file the necessary bugs against NSS and PSM to effect the approved changes? When those bugs are completed please change the status of this bug to RESOLVED FIXED.

Thanks in advance!

Comment 17

[Kathleen Wilson]

I have filed bug 499712 against NSS and bug 499716 against PSM for the actual changes.

Comment 18

[Kathleen Wilson]

Confirmed that these roots are Builtin Object Tokens in Firefox 3.6.