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Isn't provisioning certs without at least a simple human interaction from the domain holder against CA rules?



Well having a website hosted on Cloudflare implies that you had more interaction than most CAs will ever ask you to get a certificate, that is beside giving them the money.


No, I don't think that exists at least in the CA/B Baseline. You have to have consent, obviously, but that's obtained when you sign up for CloudFlare.


Consent yes, though I can't fully parse "procedures established by". What procedures are meant here?

https://cabforum.org/wp-content/uploads/Baseline_Requirement...

"The CA MUST ensure that the certificate is issued with the consent of, and according to procedures established by, the owner of each Domain Name"

EDIT: Here are the established authorization procedures:

"11.1.1 Authorization by Domain Name Registrant

For each Fully-Qualified Domain Name listed in a Certificate, the CA SHALL confirm that, as of the date the Certificate was issued, the Applicant (or the Applicant’s Parent Company, Subsidiary Company, or Affiliate, collectively referred to as “Applicant” for the purposes of this section) either is the Domain Name Registrant or hascontrol over the FQDN by:

1. Confirming the Applicant as the Domain Name Registrant directly with the Domain Name Registrar;

2. Communicating directly with the Domain Name Registrant using an address, email, or telephone number provided by the Domain Name Registrar;

3. Communicating directly with the Domain Name Registrant using the contact information listed in the WHOIS record’s “registrant”, “technical”, or “administrative” field;

4. Communicating with the Domain’s administrator using an email address created by pre-pending ‘admin’, ‘administrator’, ‘webmaster’, ‘hostmaster’, or ‘postmaster’ inthe local part, followed by the at-sign (“@”), followed by the Domain Name, which may be formed by pruning zero or more components from the requested FQDN;

5. Relying upon a Domain Authorization Document;

6. Having the Applicant demonstrate practical control over the FQDN by making an agreed-upon change to information found on an online Web page identified by a uniform resource identifier containing the FQDN; or 7. Using any other method of confirmation, provided that the CA maintains documented evidence that the method of confirmation establishes that the Applicant is the Domain Name Registrant or has control over the FQDN to at least the same level of assurance as those methods previously described. "

IANAL and I'm sure that CF has had this double checked, but I still think it's a bold move to issue certs on their own account.


> Having the Applicant demonstrate practical control over the FQDN by making an agreed-upon change to information found on an online Web page identified by a uniform resource identifier containing the FQDN

CloudFlare arguably has the consent of the domain holder (gray area but probably in CF's favor) and can pass the required validation.

I do partially agree that the domain holder (CloudFlare's customer) should have been sent an opt-in email, but I think the positives outweigh the negatives.


For Cloudflare to work, they require that you use their DNS servers on the domain so that provides good validation.




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