It will not come as a surprise that I oppose adoption for the reasons laid out in 'Trust is non-negotiable' [1].

The claims that Trust Negotiation can improve security or compatibility just do not stand up to scrutiny. Especially as in over a year since first introduction, there has been no credible proposal for how TN could be deployed outside of browsers and major CDNs or how it could bring any benefit at all with such a limited scope for deployment. It's not like major CDNs struggle to offer certificates suitable for browsers.

Even if the deployability concerns could be solved and so Trust Negotiation enabled at scale, then it would cause much more harm than good. Managing one certificate chain and CA relationship is already painful for many website operators, but TN would compound that pain by allowing root programs to diverge and placing the onus on website operators to obtain and manage multiple certificate chains to ensure compatibility with each root program's clients.

It would also be a major abuse vector for users, who are much more likely to suffer than benefit from the resulting fragmentation of the WebPKI, as well as being put at risk by use of TN to establish new root programs with malicious or negligent stewardship (domestic PKIs, enshittification, ossification).

In both cases, the result is a claimed reduction in operational burden for root programs and major CDNs (who have the most capacity and expertise to handle it) and the very material transfer of risk and complexity to users and website operators (who are least well equipped).

As technologists evaluating a proposal that would alter the architecture of one of the Internet's most critical ecosystems, we owe users and website operators better.

Best,
Dennis

[1] https://datatracker.ietf.org/doc/html/draft-jackson-tls-trust-is-nonnegotiable





----

Below the fold, some comments on the discussion so far:

*On Cross Signing
*

The current solution to trust anchor agility is path building / cross-signing. [...] I firmly believe that path building is unsalvageable. In addition to the interim discussions, this blog post [2] by Ryan Sleevi was very convincing to me.

I read Ryan's blog post and came to some very different conclusions.

Doing path building 'right' was a problem solved a very long time ago in browsers and many other implementations. Implementations that still aren't getting it right today simply don't care about the problem enough to fix it. If they did care, they would just fix their implementation, as indeed OpenSSL had already done 2 years before Ryan's blog post was published.

Your argument rests on the idea that someone not doing path building correctly today would be willing to do the extra work of implementing TAI (including the necessary API changes and DNS integration) and would implement it correctly, but would be unwilling to make the smaller and simpler changes to fix up their path building implementation. This doesn't make much sense.

*On coming PKI transitions
*

My interest is particularly in the WebPKI space, where annual removals of web trust bits starting this year will make finding common trust amongst clients an exponentially harder problem over time.
Looking at the kind of time its taken to get TLS 1.3, QUIC, ECH and other standards into the wider world, I think this perspective is extremely optimistic. No matter what, root programs are going to be managing the coming root transitions exclusively with cross-signing.

*On dealing with issues post-adoption*

I feel it’s appropriate for the working group to adopt. We can always stop before standardizing, or not deploy this stuff, when it becomes clear we were wrong.

Once the code has shipped, the genie doesn't go easily back into the bottle. There's a right time to address these issues and that's as early as possible.

[2] https://medium.com/@sleevi_/path-building-vs-path-verifying-the-chain-of-pain-9fbab861d7d6



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