Earlier today, news began to spread about an exploited certification authority (CA) spotted in the wild. The Tor project blog has an excellent write-up on how they detected the presence of patches blocking particular SSL certificates and worked backwards to determine that a Comodo issuer had been compromised. The folks at Tor suppose (rightly) that if people who monitor the patches for Firefox and Chrome hadn’t noticed, this entire incident might have been swept under the rug. Since that time, Comodo has come clean with an incident report which describes in detail the certificates that were issued and even states


 All of the above leads us to one conclusion only:- that this was likely to be a state-driven attack.

I am not as convinced – I think it might have been referenced more to try to deflect interest and speculation away from their own poor management. Also, I would think that a state attack would be more involved than a simple username and password.

Yes, Comodo notes in a separate blog post that the compromise was related to the theft of a username and password of a registration authority (RA) account. I was shocked to find out that their registration authority users are able to log in with a username and password, and not requiring a more secure method of login (for example, public key infrastructure (PKI) login with a smart card). I took a look at the Comodo Certification Practice Statement (CPS) and found that “Trusted roles” (section 3.10.1) should in fact require it. The CPS states (for Trusted personnel) “Identification is via a username, with authentication requiring a password and digital certificate.”

Of course my first issue is with the semantics of the statement.  Presenting a digital certificate is not authenticating anything because digital certificates are public information; one must prove the possession of the private key corresponding to the digital certificate to be authenticated.

My second issue is that it is not clear in the CPS whether an RA would actually be a “Trusted role” or not. In section 3.9.3 they indicate the following:

All personnel in trusted positions handle all information in strict confidence. Personnel of RA/LRAs especially must comply with the requirements of the English law on the protection of personal data.

To me, this reads that personnel of RA/LRAs are “personnel in trusted positions” and therefore should qualify for the “Trusted role” in their CPS, which would have required certificate-based login. Unfortunately, I cannot find any more definitive statements in the CPS that would put the RA into or out of the “Trusted role” as defined.

Ultimately, I hope this compromise will help Comodo improve their practices and update their policies. Most organizations that run a PKI (whether internal or external) know that RAs should always be considered a trusted role in a PKI. The RA’s role is to direct the actions of the CA, the entity that issues the certificates and certificate status information. These certificates, in turn, allow us to trust transactions between parties (such as SSL sessions). If the RA is not trusted, then nothing in the PKI should be.

2 thoughts on “Did Comodo violate its own practices?

  1. Paul says:

    What about the validation it self.. almost everyone could become a Comodo RA. Why are there no default checks?

    It’s not the first or second time something like this happens to Comodo, maybe there is just something wrong with this CA.


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