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Certificate Authority Trustworthiness

By Robert Alexander


The certificate authority (CA) system does an incredible job of solving an impossible challenge. Think about it. The CAs measure control of a domain name and then issue TLS certificates that pair cryptographic keys to those names. They do this on a global scale, often automatically. It's impossible to do this perfectly, and unfortunately, they occasionally fail.

In this post I describe the challenges the CAs face, describe a history of failures, and explain the process we use to maintain confidence in the system in spite of it all.


The certificate authorities (CAs) solve a foundational key exchange problem for the Internet. They allow us to authenticate the TLS keys used by web servers, which they do by verifying control of domain names and signing certificates that associate public keys with these names. Authentication is a critical part of encrypting communications. Without authentication you may be encrypting with an attacker's key, allowing them to eavesdrop on or tamper with your data in transit.

Methods like certificate pinning work for things like IoT or mobile applications that communicate with a single back-end server. The developer can hardcode the certificate fingerprint and push an update any time it changes. But pinning doesn't scale for websites or email. We need something Internet-scale, and we've got the CAs.

A history of security concerns

Mozilla maintains a long list of CA compliance bugs that tracks over a thousand concerns. Most of these aren't worth discussing, so let's start with noteworthy CA-related problems from the past year:

November 2022
An Internet-facing administration tool used by the e-Tugra CA had a wide-open sign-up page that allowed Ian Carrol, a security researcher, to register an account and view sensitive content. Of top concern: the confirmation codes used by the email domain control validation (DCV) method were visible. With this access the security researcher could have started a certificate signing request for a domain they didn't own, chosen the email DCV, and then intercepted the confirmation code via the administration tool1. e-Tugra fixed the issue when notified, but the community acknowledged "this isn't a little mistake". Chrome and Mozilla distrusted e-Tugra after around six months of discussion.

November 2022
Trustcor appeared to have "shared corporate officers, operational control and technical integrations" with Measurement Systems, which "engaged in the distribution of an SDK containing malware". Chrome distrusted the CA, citing a loss of confidence: "Behavior that attempts to degrade or subvert security and privacy on the web is incompatible with organizations whose CA certificates are included in the Chrome Root Store." Trustcor contested the claims as "opinion, circumstantial evidence, conjecture, and fear-mongering".

July 2023
HiCA used a remote code execution exploit on users' systems as part of a certificate issuance process. While HiCA's use of this technique wasn't malicious, the approach was immediately treated as a security vulnerability and fixed once proper notification was given. The concern was briefly discussed on the Mozilla forum, which acknowledged that HiCA is not a CA. HiCA was assisting in the certificate issuance process using an actual CA, using a process that was otherwise by the book. "Literally anyone can do this and do monumentally stupid/insecure things; it's not productive to have a discussion every time this happens." No action was recommended as the browsers decide on CA trust, not tools or 3rd parties that users choose to assist the issuance process. HiCA shut down soon after these events, citing security incidents.

March 2022
An unnamed CA was hacked as part of a suspected state-sponsored hacking campaign also targeting government agencies and defense contractors. There is "no evidence to suggest [the hackers] were successful in compromising digital certificates". The lack of clarity on which CA was hacked, how they were hacked, and the lack of adequate public disclosure is troubling.

There are many more of these that are older, but I think the recent events tell the story well2.

The above shows successful attacks, poor security practices, and questionable organizations. While these are concerning, none of these events appear to have caused actual certificate mis-issuance3. The web browsers carefully consider the risk of maintaining trust relationships when these sorts of events happen, sometimes revoking trust after a thorough review.

Mis-issuances occur somewhat rarely, let's look further back in time.

MCS Holding
March 2015
MCS Holdings, an intermediary CA, mis-issued certificates for various domains, including Google's. These certificates appeared to be used for an internal man-in-the-middle proxy, but not external to the company. Google immediately distrusted the intermediary CA and quickly distrusted CNNIC, the root CA used by MCS Holdings.

December 2013
A similar incident occurred with ANSSI.

July 2011
Hackers fraudulently obtained certificates from the DigiNotar CA for,,,, and more totaling 531 certificates in all. An active man-in-the-middle attack using these certificates was performed against users connecting to Google's services. The trust in DigiNotar was revoked and the company soon filed for bankruptcy.

The DigiNotar hack is a textbook example of what we don't want. The hackers not only compromised the CA, but they also fraudulently issued certificates, established a man-in-the-middle network position and intercepted the emails of 300,000 people. Thankfully, the DigiNotar hack is an outlier.

Trust root inclusions and denials

Each web browser maintains a list of the CAs they trust out-of-the-box. As we've already seen, this trust can be revoked when problems arise. But what's the inclusion process?

Review is process heavy, focusing on security assurance and the trustworthiness of the organization operating the CA. There are independent audits and security standards. In the end, it's a subjective decision with lots of supporting documentation.

For transparency, Mozilla and the CA/Browser Forum use public discussion when deciding if a new CA should be added as a trust root. There are many boring examples that prompt little debate, like the inclusion request LAWtrust.

The denials can be terrifying:

Attackers focus elsewhere

A rough way to measure the security of a system is to observe how often it is attacked versus adjacent areas. Attackers have limited resources, so they are biased to choose the weakest links (or perceived weakest). Here are some examples of how attackers bypass the protections the CAs provide, without attacking the CAs directly:

Opportunity to attack the CAs exists, but these adjacent attacks are significantly more common.

Irrevocable Trust

CA root certificates are long lived, up to 25 years. The DigiNotar root certificates that were maliciously used by hackers in 2011 are still not expired. So active revocations are required when issues arise.

Unfortunately, even when the root certificates expire, they don't really expire. Many consumer devices contain hard-coded trust stores that stop getting updated soon after the initial sale. This was a concern for Let's Encrypt when the IdenTrust DST Root CA X3 root certificate expired. Around a third of Android devices trusted the expiring root certificate, but hadn't been updated to trust Let's Encrypt's new root. IdenTrust agreed to sign Let's Encrypt's ISRG Root X1 certificate past the expiration of their own trust root. This worked because Android doesn't enforce the expiration of its trust roots.

While this approach allowed many old Android devices to be usable, it underscores a problem. The CAs often cannot be distrusted, not via software update nor expiration dates. As such, some devices will forever trust the problematic CAs referenced earlier in the post.

Government control of CAs

A recurring topic of discussion is government coercion of the CAs. Every CA operates within the jurisdiction of a government which can exert legal pressure on the CA. Many countries have laws that compel technology companies to assist the government in certain circumstances. The CAs promise not to mis-issue certificates, but a request from their government could supersede that promise.

Understanding the legal exposure of a CA is a complicated question of foreign law. Since revoking a trust root isn't always possible, it's also an exercise in predicting how laws may change.

Given those concerns, you may be surprised to know that some of the CAs are directly operated by government agencies. Here are several from the Microsoft trust store:

Historic trust also existed for:

The Mozilla list and Google list are much shorter than Microsoft's list. Unfortunately, Microsoft doesn't operate a public discussion forum, so the purpose and justification of these inclusions is not apparent.

One of the most important functions of a government is to provide services to its people. It's common for governments to provide security services, issue identity documents, and handle delivery of postal mail, for example. I don't think it's unusual for governments to seek to provide Internet-based identity services. But there is a conflict of interest, as governments also perform law enforcement, intelligence, and military operations. The global reach a government-operated CA has may not be appropriate.

Trusting the system

With all these problems, why do we still trust the CA system?

One reason is the lack of a better alternative. I'm planning to post about DNSSEC+DANE soon, but in short: it's a mess. This is an incredibly hard problem space, and nothing else is viable.

The web browsers have done an excellent job defining security standards, reviewing inclusion requests, considering revocations, and being transparent to the users about their decisions. It's a dynamic process needing constant attention and vigilance. Requiring certificate transparency logs (a public log of every issued certificate) provides great tooling to audit the issuance practices and swiftly detect problems. Recent improvements like Certificate Authority Authorization (CAA) reduce the impact of certain classes of CA security incidents. Attacks like the DigiNotar hack are much easier to detect these days and we have tools to reduce impact.

Call to action

The large number of attacks impacting adjacent systems is a strong signal that effort is best spent securing those adjacent systems. Security isn't about perfection, it's about strengthening weak areas. With that said, I think there's still high-value work to be done here.

Transparent inclusion decisions

This post is heavily references actions of the Mozilla trust store, largely due to the public discussion forum they use. Without such public discussion users have no idea what the inclusion process looked like. Sometimes objections are raised and the justification used for inclusion helps concerned users understand the nuance of the role the CAs fill. Microsoft, Apple, and Google own major web browsers but do not provide an equivalent open discussion forum. Each browser trusts a distinct set of trusted CAs, so the justification for inclusion can't always be inferred from Mozilla's forum.

You can review these lists here:

Bug Bounties

None of the CAs offer bug bounties, they instead rely on private auditors. There's clearly low-hanging fruit the auditors are missing. Bug bounties are a great way to encourage altruistic hackers to take a look at your security while providing safe harbor. Without these incentives, less scrupulous hackers will look anyway and may sell their findings to malicious actors.

Upgradable trust stores

Some devices can be challenging to update, especially if they are abandoned by the manufacturer. Let's Encrypt had this issue when they were getting started as a CA, particularly for Android devices. The only way to mass deploy updates to the trust store on Android is via over-the-air (OTA) updates. Thankfully Android is fixing this issue by adding updatable trust stores. All devices should support updating trust stores.

Smaller trust stores

If Chrome doesn't trust a CA, why should my Firefox browser trust it? And vice versa. Any competently operated website wouldn't use a CA that isn't widely trusted, so the loss of functionality should be marginal. When a distrust action is taken, it's common for all the trust stores to agree on revocation, but decisions don't always happen at the same time. Custom browser builds with a security focus should use a trust store that only includes trust roots that are in all the major browser trust stores. Better UX can be helpful for end-user pruning of trust roots.


1. CAA could protect a domain from this sort of attack. Imagine an attacker who can spoof challenge responses for a single CA, thereby fraudulently creating certificates. A domain owner who had enabled CAA for their domain would be immune to this attack unless they had chosen the affected CA.

2. I've excluded a security incident at Entrust as it didn't impact their PKI business.

3. This post is focused on certificates used to secure HTTPS/TLS connections but there are other uses, like code signing. Incidents like this 2021 security lapse where an attacker tricked Microsoft into signing malware are out of scope.

4. I've posted before about the issues with name constraints. Even when there's intent to constrain a CA's root certificate to a particular TLD, like discussed in this request, the name constraint feature isn't used.

Hello! I'm Robert Alexander, a freelance software developer and security consultant. This blog features some of my work and thoughts on software, the cloud, and security. You can get updates on my posts with your favorite RSS client or on Substack. I'm also on Mastodon.