Building a certificate authority for the whole Internet
blog.cloudflare.com
blog.cloudflare.com
Now, it looks like WebPKI is going to fracture into two regarding PQ Crypto. With Google (GTS and Chrome), Cloudflare and Let's Encrypt all preferring MTC and legacy CA's like Digicert, Sectigo, Globalsign all heading towards non MTC.
If Cloudflare would not have decied to become a PQ CA for MTC. We would have a duopoly with GTS and Let's Encrypt. This is a worse off situation. Therefore I welcome Cloudflare CA for MTC.
Also, its not like they are going to make any money of the CA business if they are going to issue DV certs for free. It will reduce the pressure on Let's Encrypt from carrying the burden of securing 60% of the world's webistes.
It's not freeloading to accept a gift freely given. I'm sure the people who do fund LE are happy to see the world's largest TLS terminator using LE certs to secure the web - that is and was the whole point of LE in the first place. It's being used as intended.
1. We have seen how Cloudflare can "break the Internet" due to their position as a SPoF. Let's Encrypt also became a SPoF as their popularity grew.
2. Cloudflare's main service depends on breaking the trust model of TLS, which is to say that users must be assured that they can communicate with a server without the possibility that third parties are observing or tampering with the connection. If I direct my user agent to example.com, I expect that my TLS connection is terminated by the operators of example.com, and any contents sent and received are between me and the servers associated with example.com. Cloudflare breaks that assumption by performing TLS interception between my user agent and the server. Yes it is true that other services, such as cloud load balancers, do the same thing, but we should not accept that this creates an important opportunity for interception or tampering due to commercial interest, duress etc.
3. Furthermore Cloudflare allows operators to present a TLS certificate to clients even when the origin server does not use TLS, leading them to believe that their connection is secure even when the leg between Cloudflare and the server is not encrypted: the so-called TLS façade.
4. Cloudflare is incorporated in a jurisdiction that has been seen to behave in a hostile, or at a minimum highly arbitrary, fashion, and has been involved in pressuring infrastructure operators to do their geopolitical bidding and personal favors to the executive. Of course Let's Encrypt also has this weakness.
Are we to believe it is a good thing that a known SPoF becomes an even more critical SPoF? That an actor who subverts TLS becomes a CA? More concentration of infrastructure control in a single jurisdiction that does not respect international norms?
Cloudflare promoters will say that points 2 and 3 are always the choice of the server operator. However Cloudflare takes advantage of the fact that most server administrators actually understand very little about how TLS, or even the Internet, works. I frequently observe that the operators of critical public services on the Internet fundamentally misunderstand basic technologies such as DNS, IP, TLS and HTTP. For those people, Cloudflare gives them an easy option to "stop the DDoS", without understanding the implications of sending their traffic to a foreign actor who will perform TLS interception. And in many cases, using Cloudflare turns into a ritualistic mimicry that is performed as a preventative rite to placate the DDoS spirits.
It is also concerning to me the suggestion that CAs which are not GTS, CF and LE are somehow considered "legacy CAs" now. In what sense?
LE recently updated their policies to say explicitly that they will comply with export restrictions:
https://letsencrypt.org/documents/LE-SA-v1.7-June-04-2026-di...
Discussion: https://news.ycombinator.com/item?id=48453275
Let me remind you that the implied "modern" CAs mentioned must also comply with export restrictions, but furthermore they are subject to non-public pressure dynamics from the executive which may result in arbitrary service terminations at the individual, organization or country levels. This as well as compliance requirements with CLOUD and collection programs.
I propose that the goal should be to look for a way in which we can have widespread availability of free DV certificates for everyone who needs one, independent of their nationality, from multiple geographically distributed providers in diverse jurisdictions, coupled with a sustainable economic model for CAs which are not operated by the tech behemoths.
There are actually non-behemoth CAs, besides LE, which already provide free DV certs, ACME compatible, for example:
https://www.ssl.com/products/website-security/tls-ssl/single...
"On October 19, 2015, the intermediate certificates became cross-signed by IdenTrust, causing all certificates issued by Let's Encrypt to be trusted by all major browsers."
https://cabforum.org/working-groups/server/baseline-requirem...
If a bad actor starts buying up CA's, then very quickly that CA would be distrusted by Root Cert Store Operators. No different than what happened with DigiNotr and Entrust.
CloudFlare was launched as a stupid-simple CDN, but DDoS mitigation and bot reduction are actually valuable features for many websites. Sure, CF isn't the only business in this space, but most of their rivals are large enough to be in the S&P500 / Russell 2000, so it's not like garage startups are competing for this business.
"Was meant to be"
This isn't a law of physics. This was a starry-eyed hope by techno-utopians and academics when the internet was still 100% funded by Uncle Sam. When the internet moved out of its parents' basement, it had to grow up and get a job to pay the bills. Some people are fine with a SquareSpace webpage instead of running their own custom Apache httpd website on bare metal in a colo like it's 2005. The cost of maintenance and cognitive load is a cost we shouldn't ignore.
It turns out that economies of scale exist. The Internet doesn't need 10,000 small CDNs and they would all be inefficient and expensive if that was the distribution. Instead, there are a few large ones that can afford to colo in many geographically dispersed data centers and who negotiated bandwidth peering contracts for advantageous pricing.
Surprise! It's on crimeflare.
> DDoS-for-hire cost only a few dollars per minute
I imagine those two are closely related. If not for Cloudflare and similar offers, we would spend more effort & resources on non-symptomatic treatment of internet-scale bad actors and its enablers (lately, more under-maintained "smart" devices than dumb modems, I hear). Every unresolved-for-years botnet is excellent advertising for CF, and they are not even paying for it. (We are all paying for it, dearly.)
It was meant to be resilient and have multipath capability to route around damage. Having command authority sourced from multiple places was never part of the goal, and, indeed, in the client/server model that has prevailed the entire time the internet has existed, nothing about the design of the internet has been explicitly created to allow for server or data redundancy or distribution.
decentralized != distributed
Indeed, on the "modern internet" (aka the last 25+ years), everyone uses NAT, which means that end to end connectivity is not needed or wanted by most users and engineers. This idea that "every host should have a public IP, and every host should be a server as well as a client" is just fantasy that has no basis in reality, either in intent, or in practice.
That sounds awfully sympathetic to the "only revoke if/when convenient" bullshit Telekom Security et al pulled off. I was hoping for something closer to:
We have seen certificate authorities extend promises to their customers that they knew to be fundamentally incompatible with their committed obligations to the CA/B & the wider internet. We intend to do better than that. We will not hide behind claiming it was inconvenient to fulfill our duties that come with operating a public CA. Our customers will be prepared for whatever revocation that we might be required to execute.
> anyone already pointed at any existing free CA can move to us by changing a directory URL, with no new tooling and nothing to re-architect.
> We will only issue to clients that support ACME Renewal Information (ARI), standardized in RFC 9773.
I do not think both can be true.
> What on Earth makes you think that they are any sort of gatekeeper of the web?
Unfortunately, site operators have to operate on the Internet we actually have, full of DDoS attacks and wanton scrapers, so a sufficient number of site operators have chosen to use Cloudflare, so as to reduce their burden, so in isolation, yeah, sure, the problem is that in aggregate, they do have keys to the gate of sufficiently large swaths of the Internet, that they are de facto gatekeepers of that particular portion of the Internet.
If you are privileged enough to be able to opt out of that portion of the Internet, count yourself lucky!
I don't think we will see Cloudflare enabling an "age assurance" requirement by default. I feel like I could trust them slightly more than a site operator, depending on how it's performed, but I also feel like it would be very easy for them to do much, much worse than any site operator, due to the inherent power of being a GAA. (Global Active Adversary, to those not familiar)
It's the same issue I have with laptops that aren't MacBooks -- you cannot always just fix an issue with a MacBook by choosing something else. Often, that something else lacks everything good about the MacBook and you'll have even more problems.
Also, not everyone has implicit trust in everyone else's future direction. No outsider could have known they would do this! The only reason you could've chosen them for it is if you already agreed with this default. It's entirely fair to push back against defaults you disagree with. Especially when stuff like this suddenly makes a majority of the internet way worse for users.
Note that I don't disagree with blocking bots in general, especially when you need it to prevent your site from crashing, etc. I disagree with making everyone have to opt out if they don't want to block bots like that. That will lead to most operators not doing anything, and most sites blocking bots by default, even when they never actually would have otherwise!
You have access to unlimited free certificates based on DNS delegation through this method, but need more.
It might be useful to explain why this adds value that another CA can't