>RFC8446bis explicitly defines key reuse as a SHOULD NOT.

It would be good if RFC8446bis could clarify what this 'key reuse' means. As 
discussed earlier, this term can have at least three very different meanings. 
Many formal analysis experts have understood TLS 1.3 as specifying that keys 
should be used for only one execution of key establishment.
https://mailarchive.ietf.org/arch/msg/tls/MOqSAplAYQuA6AwkKfHCphQUlKU/

If 'key reuse' includes using the same key in more than one execution of key 
establishment, RFC 8446bis should explain that such 'key reuse' undermines 
forward secrecy and makes exploitation of side-channel attacks and 
implementation flaws much easier.

While RFC 8446 fails to define the term 'ephemeral', specifications using 
ML-KEM points normatively to FIPS 203, which in turn points normatively to SP 
800-227, which has very precise definitions for 'ephemeral' and 'static'. Since 
X25519MLKEM768 is already the de facto standard for TLS key exchange, TLS 
specifications should avoid using the terms 'ephemeral' and 'static' in ways 
that conflict with FIPS 203.

I do not oppose other people using static keys in TLS for visibility; I just 
strongly agree with SP 1800-37 that it is a bad solution for visibility, and if 
allowed in a TLS WG document, the security implications should be clearly 
described.

I am not sure whether the current situation is the result of ideological 
fighting, privacy theater, or a combination of both. Beyond the existing 
uncertainty regarding whether static keys are permitted, the current approach 
of not explicitly negotiating static keys is strictly worse than the solutions 
in TLS 1.2 and in draft-rhrd-tls-tls13-visibility.

Cheers,
John Preuß Mattsson

From: Joseph Salowey <[email protected]>
Date: Saturday, 28 February 2026 at 02:04
To:
<[email protected]>
Subject: [TLS] Clarification on the FATT Process

In the FATT process, working group chairs decide at the time of adoption 
whether a document needs FATT review.

>From https://github.com/tlswg/tls-fatt:

"When a document is adopted by the working group the chairs will make a 
determination whether the change proposed by the document requires review by 
the FATT to determine if formal protocol analysis is necessary for the change. 
For example a proposal that modifies the TLS key schedule or the authentication 
process or any other part of the cryptographic protocol that has been formally 
modeled and analyzed in the past would likely result in asking the FATT, 
whereas a change such as modifying the SSLKEYLOG format would not. The working 
group chairs will inform the working group of this decision."

The chairs made this decision because the mechanism in this draft fits into a 
well defined place in the TLS protocol and does not change the protocol itself. 
The purpose of the FATT is to evaluate the potential security impact of a 
change in the protocol, not to evaluate the merits of a specific cryptographic 
algorithm such as ML-KEM. Unfortunately, the chairs did not announce this 
decision on the list (this is something that should be corrected in the process)

This decision is supported by references from Thom Wiggers and others on the 
list that identify the security properties required by TLS 1.3 key exchange.

The ML-KEM draft does not modify the TLS key schedule or protocol messages in 
any way other than what is anticipated by RFC 8446/8446bis. RFC8446bis 
explicitly defines key reuse as a SHOULD NOT.

The considerations applied also for ecdhe-mlkem, which has already gone through 
the WG process and also did not undergo FATT review.

Joe
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