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Recently, a rogue WHOIS server enabled researchers from WatchTowr Labs to exploit WHOIS to obtain fraudulently issued TLS certificates. In the CA/Browser forum*, this event led Google to propose a ballot to sunset the use of WHOIS for identifying domain contacts.
Google's latest ballot draft would set the following prohibitions starting 15 January 2025:
DigiCert does not support the ballot as currently written, as it does not yet incorporate the sensible feedback provided by ICANN nor the more reasonable timeline proposed by Amazon. We do support moving away from the obsolete WHOIS protocol to the more modern RDAP protocol while giving customers a reasonable amount of time to migrate and update their validation infrastructure. While we appreciate Google’s recent statements that they may be flexible on the timeline, customers need to be aware that this ballot will likely pass in some form.
*Note: In digital trust, the Certificate Authority/Browser Forum (CA/B Forum) writes the Baseline Requirements for the issuance and management of publicly trusted digital certificates, such as TLS, code signing, and S/MIME certificates. Enforcement of the requirements is handled by browser root programs.
If the ballot passes, starting 15 January 2025 at 00:00 UTC, you could no longer use the WHOIS-based email domain control validation (DCV) method to demonstrate control over a domain. For this DCV method, DigiCert sends an authorization email to the registered owners of the public domain, as shown in the domain's WHOIS record.
Additionally, starting 15 January 2025, CAs, such as DigiCert, could not reuse existing WHOIS-based domain validation to reissue or renew a certificate, forcing you to revalidate the domains using a different DCV method.
As soon as 15 January 2025, you would have to use a different DCV method to demonstrate control over your domains. You can still use the email DCV method; however, you must use the Constructed Email or Email to DNS TXT contact email DCV method.
DigiCert Recommendation
The industry is aligned with moving away from using WHOIS to identify domain contacts. So, DigiCert recommends that those using the WHOIS-based Email DCV method update their domain validation processes to use one of the other supported DCV methods as soon as possible.
DigiCert currently supports these other DCV Methods:
If you have questions or concerns about this ballot prohibiting the use of WHOIS for identifying domain contacts, please contact your account manager or DigiCert Support immediately - Contact DigiCert.