Category Archives: Standards

Compliance at the Speed of Code

Compliance is a vital sign of organizational health. When it trends the wrong way, it signals deeper problems: processes that can’t be reproduced, controls that exist only on paper, drift accumulating quietly until trust evaporates all at once.

The pattern is predictable. Gradual decay, ignored signals, sudden collapse. Different industries, different frameworks, same structural outcome. (I wrote about this pattern here.)

But something changed. AI is rewriting how software gets built, and compliance hasn’t kept up.

Satya Nadella recently said that as much as 30% of Microsoft’s production code is now written by AI. Sundar Pichai put Google’s number in the same range. These aren’t marketing exaggerations; they mark a structural change in how software gets built.

Developers no longer spend their days typing every line. They spend them steering, reviewing, and debugging. AI fills in the patterns, and the humans decide what matters. The baseline of productivity has shifted.

Compliance has not. Its rhythms remain tied to quarterly reviews, annual audits, static documents, and ritualized fire drills. Software races forward at machine speed while compliance plods at audit speed. That mismatch isn’t just inefficient. It guarantees drift, brittleness, and the illusion that collapse comes without warning.

If compliance is the vital sign, how do you measure it at the speed of code?

What follows is not a description of today’s compliance tools. It’s a vision for where compliance infrastructure needs to go. The technology exists. The patterns are proven in adjacent domains. What’s missing is integration. This is the system compliance needs to become.

The Velocity Mismatch

The old world of software was already hard on compliance. Humans writing code line by line could outpace annual audits easily enough. The new world makes the mismatch terminal.

If a third of all production code at the largest software companies is now AI-written, then code volume, change velocity, and dependency churn have all exploded. Modern development operates in hours and minutes, not quarters and years.

Compliance, by contrast, still moves at the speed of filing cabinets. Controls are cross-referenced manually. Policies live in static documents. Audits happen long after the fact, by which point the patient has either recovered or died. By the time anyone checks, the system has already changed again.

Drift follows. Exceptions pile up quietly. Compensating controls are scribbled into risk registers. Documentation diverges from practice. On paper, everything looks fine. In reality, the brakes don’t match the car.

It’s like running a Formula 1 car with horse cart brakes. You might get a few laps in. The car will move, and at first nothing looks wrong. But eventually the brakes fail, and when they do the crash looks sudden. The truth is that failure was inevitable from the moment someone strapped cart parts onto a race car.

Compliance today is a system designed for the pace of yesterday, now yoked to the speed of code. Drift isn’t a bug. It’s baked into the mismatch.

The Integration Gap

Compliance breaks at the integration point. When policies live in Confluence and code lives in version control, drift isn’t a defect. It’s physics. Disconnected systems diverge.

The gap between documentation and reality is where compliance becomes theater. PDFs can claim controls exist while repos tell a different story.

Annual audits sample: pull some code, check some logs, verify some procedures. Sampling only tells you what was true that instant, not whether controls remain in place tomorrow or were there yesterday before auditors arrived.

Eliminate the gap entirely.

Policies as Code

Version control becomes the shared foundation for both code and compliance.

Policies, procedures, runbooks, and playbooks become versioned artifacts in the same system where code lives. Not PDFs stored in SharePoint. Not wiki pages anyone can edit without review. Markdown files in repositories, reviewed through pull requests, with approval workflows and change history. Governance without version control is theater.

When a policy changes, you see the diff. When someone proposes an exception (a documented deviation from policy), it’s a commit with a reviewer. When an auditor asks for the access control policy that was in effect six months ago, you check it out from the repo. The audit trail is the git history. Reproducibility by construction.

Governance artifacts get the same discipline as code. Policies go through PR review. Changes require approvals from designated owners. Every modification is logged, attributed, and traceable. You can’t silently edit the past.

Once policies live in version control, compliance checks run against them automatically. Code and configuration changes get checked against the current policy state as they happen. Not quarterly, not at audit time, but at pull request time.

When policy changes, you immediately see what’s now out of compliance. New PCI requirement lands? The system diffs the old policy against the new one, scans your infrastructure, and surfaces what needs updating. Gap analysis becomes continuous, not an annual fire drill that takes two months and produces a 60-page spreadsheet no one reads.

Risk acceptance becomes explicit and tracked. Not every violation is blocking, but every violation is visible. “We’re accepting this S3 bucket configuration until Q3 migration” becomes a tracked decision in the repo with an owner, an expiration date, and compensating controls. The weighted risk model has teeth because the risk decisions themselves are versioned and auditable.

Monitoring Both Sides of the Gap

Governance requirements evolve. Frameworks update. If you’re not watching, surprises arrive weeks before an audit.

Organizations treat this as inevitable, scrambling when SOC 2 adds trust service criteria or PCI-DSS publishes a new version. The fire drill becomes routine.

But these changes are public. Machines can monitor for updates, parse the diffs, and surface what shifted. Auditors bring surprises. Machines should not.

Combine external monitoring with internal monitoring and you close the loop. When a new requirement lands, you immediately see its impact on your actual code and configuration.

SOC 2 adds a requirement for encryption key rotation every 90 days? The system scans your infrastructure, identifies 12 services that rotate keys annually, and surfaces the gap months ahead. You have time to plan, size the effort, build it into the roadmap.

This transforms compliance from reactive to predictive. You see requirements as they emerge and measure their impact before they become mandatory. The planning horizon extends from weeks to quarters.

From Vibe Coding to Vibe Compliance

Developers have already adapted to AI-augmented work. They call it “vibe coding.” The AI fills in the routine structures and syntax while humans focus on steering, debugging edge cases, and deciding what matters. The job shifted from writing every line to shaping direction. The work moved from typing to choosing.

Compliance will follow the same curve. The rote work gets automated. Mapping requirements across frameworks, checklist validations, evidence collection. AI reads the policy docs, scans the codebase, flags the gaps, suggests remediations. What remains for humans is judgment: Is this evidence meaningful? Is this control reproducible? Is this risk acceptable given these compensating controls?

This doesn’t eliminate compliance professionals any more than AI eliminated engineers. It makes them more valuable. Freed from clerical box-checking, they become what they should have been all along: stewards of resilience rather than producers of audit artifacts.

The output changes too. The goal is no longer just producing an audit report to wave at procurement. The goal is producing telemetry showing whether the organization is actually healthy, whether controls are reproducible, whether drift is accumulating.

Continuous Verification

What does compliance infrastructure look like when it matches the speed of code?

A bot comments on pull requests. A developer changes an AWS IAM policy. Before the PR merges, an automated check runs: does this comply with the principle of least privilege defined in access-control.md? Does it match the approved exception for the analytics service? If not, the PR is flagged. The feedback is immediate, contextual, and actionable.

Deployment gates check compliance before code ships. A service tries to deploy without the required logging configuration. The pipeline fails with a clear message: “This deployment violates audit-logging-policy.md section 3.1. Either add structured logging or file an exception in exceptions/logging-exception-2025-q4.md.”

Dashboards update in real time, not once per quarter. Compliance posture is visible continuously. When drift occurs (when someone disables MFA on a privileged account, or when a certificate approaches expiration without renewal) it shows up immediately, not six months later during an audit.

Weighted risk with explicit compensating controls. Not binary red/green status, but a spectrum: fully compliant, compliant with approved exceptions, non-compliant with compensating controls and documented risk acceptance, non-compliant without mitigation. Boards see the shades of fragility. Practitioners see the specifics. Everyone works from the same signal, rendered at the right level of abstraction.

The Maturity Path

Organizations don’t arrive at this state overnight. Most are still at Stage 1 or earlier, treating governance as static documents disconnected from their systems. The path forward has clear stages:

Stage 1: Baseline. Get policies, procedures, and runbooks into version-controlled repositories. Establish them as ground truth. Stop treating governance as static PDFs. This is where most organizations need to start.

Stage 2: Drift Detection. Automated checks flag when code and configuration diverge from policy. The checks run on-demand or on a schedule. Dashboards show gaps in real time. Compliance teams can see drift as it happens instead of discovering it during an audit. The feedback loop shrinks from months to days. Some organizations have built parts of this, but comprehensive drift detection remains rare.

Stage 3: Integration. Compliance checks move into the developer workflow. Bots comment on pull requests. Deployment pipelines run policy checks before shipping. The feedback loop shrinks from days to minutes. Developers see policy violations in context, in their tools, while changes are still cheap to fix. This is where the technology exists but adoption is still emerging.

Stage 4: Regulatory Watch. The system monitors upstream changes: new SOC 2 criteria, updated PCI-DSS requirements, revised GDPR guidance. When frameworks change, the system diffs the old version against the new, identifies affected controls, maps them to your current policies and infrastructure, and calculates impact. You see the size of the work, the affected systems, and the timeline before it becomes mandatory. Organizations stop firefighting and start planning quarters ahead. This capability is largely aspirational today.

Stage 5: Enforcement. Policies tie directly to what can deploy. Non-compliant changes require explicit exception approval. Risk acceptance decisions are versioned, tracked, and time-bound. The system makes the right path the easy path. Doing the wrong thing is still possible (you can always override) but the override itself becomes evidence, logged and auditable. Few organizations operate at this level today.

This isn’t about replacing human judgment with automation. It’s about making judgment cheaper to exercise. At Stage 1, compliance professionals spend most of their time hunting down evidence. At Stage 5, evidence collection is automatic, and professionals spend their time on the judgment calls: should we accept this risk? Is this compensating control sufficient? Is this policy still appropriate given how the system evolved?

The Objections

There are objections. The most common is that AI hallucinates, so how can you trust it with compliance?

Fair question. Naive AI hallucinates. But humans do too. They misread policies, miss violations, get tired, and skip steps. The compliance professional who spent eight hours mapping requirements across frameworks before lunch makes mistakes in hour nine.

Structured AI with proper constraints works differently. Give it explicit sources, defined schemas, and clear validation rules, and it performs rote work more reliably than most humans. Not because it’s smarter, but because it doesn’t get tired, doesn’t take shortcuts, and checks every line the same way every time.

The bot that flags policy violations isn’t doing unconstrained text generation. It’s diffing your code against a policy document that lives in your repo, following explicit rules, and showing its work: “This violates security-policy.md line 47, committed by [email protected] on 2025-03-15.” That isn’t hallucination. That’s reproducible evidence.

And it scales in ways humans never can. The human compliance team can review 50 pull requests a week if they’re fast. The bot reviews 500. When a new framework requirement drops, the human team takes weeks to manually map old requirements against new ones. The bot does it in minutes.

This isn’t about replacing human judgment. It’s about freeing humans from the rote work where structured AI performs better. Humans hallucinate on routine tasks. Machines don’t. Let machines do what they’re good at so humans can focus on what they’re good at: the judgment calls that actually matter.

The second objection is that tools can’t fix culture. Also true. But tools can make cultural decay visible earlier. They can force uncomfortable truths into the open.

When policies live in repos and compliance checks run on every PR, leadership can’t hide behind dashboards. If the policies say one thing and the code does another, the diff is public. If exceptions are piling up faster than they’re closed, the commit history shows it. If risk acceptance decisions keep getting extended quarter after quarter, the git log is evidence.

The system doesn’t fix culture, but it makes lying harder. Drift becomes visible in real time instead of hiding until audit season. Leaders who want to ignore compliance still can, but they have to do so explicitly, in writing, with attribution. That changes the incentive structure.

Culture won’t be saved by software. But it can’t be saved without seeing what’s real. Telemetry is the prerequisite for accountability.

The Bootstrapping Problem

If organizations are already decaying, if incentives are misaligned and compliance is already theater, how do they adopt this system?

Meet people where they are. Embed compliance in the tools developers already use.

Start with a bot that comments on pull requests. Pick one high-signal policy (the one that came up in the last audit, or the one that keeps getting violated). Write it in Markdown, commit it to a repo, add a simple check that flags violations in PRs. Feedback lands in the PR, where people already work.

This creates immediate value. Faster feedback. Issues caught before they ship. Less time in post-deployment remediation. The bot becomes useful, not bureaucratic overhead.

Once developers see value, expand coverage. Add more policies. Integrate more checks. Build the dashboard that shows posture in real time. Start with the point of maximum pain: the gap between what policies say and what code does.

Make the right thing easier than the wrong thing. That’s how you break equilibrium. Infrastructure change leads culture, not the other way around.

Flipping the Incentive Structure

Continuous compliance telemetry creates opportunities to flip the incentive structure.

The incentive problem is well-known. Corner-cutters get rewarded with velocity and lower costs. The people who invest in resilience pay the price in overhead and friction. By the time the bill comes due, the corner-cutters have moved on.

What if good compliance became economically advantageous in real time, not just insurance against future collapse?

Real-time, auditable telemetry makes compliance visible in ways annual reports never can. A cyber insurer can consume your compliance posture continuously instead of relying on a point-in-time questionnaire. Organizations that maintain strong controls get lower premiums. Rates adjust dynamically based on drift. Offer visibility into the metrics that matter and get buy-down points in return.

Customer due diligence changes shape. Vendor risk assessments that take weeks and rely on stale SOC 2 reports become real-time visibility into current compliance posture. Procurement accelerates. Contract cycles compress. Organizations that can demonstrate continuous control have competitive advantage.

Auditors spend less time collecting evidence and more time evaluating controls. When continuous compliance is demonstrable, scope reduces, costs drop, cycles shorten.

Partner onboarding that used to require months of back-and-forth security reviews happens faster when telemetry is already available. Certifications and integrations move at the speed of verification, not documentation.

The incentive structure inverts. Organizations that build continuous compliance infrastructure get rewarded immediately: lower insurance costs, faster sales cycles, reduced audit expense, easier partnerships. The people who maintain strong controls see economic benefit now, not just avoided pain later.

This is how you fix the incentive problem at scale. Make good compliance economically rational today.

The Choice Ahead

AI has already made coding a collaboration between people and machines. Compliance is next.

The routine work will become automated, fast, and good enough for the basics. That change is inevitable. The real question is what we do with the time it frees up.

Stop there, and compliance becomes theater with better graphics. Dashboards that look impressive but still tell you little about resilience.

Go further, and compliance becomes what it should have been all along: telemetry about reproducibility. A vital sign of whether the organization can sustain discipline when it matters. An early warning system that makes collapse look gradual instead of sudden.

If compliance was the vital sign of organizational decay, then this is the operating system that measures it at the speed of code.

The frameworks aren’t broken. The incentives are. The rhythms are. The integration is.

The technology to build this system exists. Version control is mature. CI/CD pipelines are ubiquitous. AI can parse policies and scan code. What’s missing is stitching the pieces together and treating compliance like production.

Compliance will change. The only question is whether it catches up to code or keeps trailing it until collapse looks sudden.

Educating the Champion, the Buyer, and the Market

Security used to be something we tried to bolt on to inherently insecure systems. In the 1990s, many believed that if we simply patched enough holes and set up enough firewalls, we could protect almost anything. Today, hard-won experience has shown that secure-by-design is the only sustainable path forward. Rather than treating security as an afterthought, we need to bake it into a system’s very foundation—from its initial design to its day-to-day operation.

Yet even the best security technology can fail to catch on if no one understands its value. In my time in the field I’ve seen a recurring theme: great solutions often falter because they aren’t communicated effectively to the right audiences. Whether you’re a security entrepreneur, an in-house security architect, or part of a larger development team, you’ll likely need to equip three distinct groups with the right messaging: the Technical Champion, the Economic Buyer, and the Broader Market. If any of them fail to see why—and how—your solution matters, momentum stalls.

From Bolt-On to Secure-by-Design

The security industry has undergone a massive shift, moving away from the idea that you can simply bolt on protection to an already flawed system. Instead, we now realize that security must be designed in from the start. This demands a lifecycle approach—it’s not enough to fix bugs after deployment or put a facade in front of a service. We have to consider how software is built, tested, deployed, and maintained over time.

This evolution requires cultural change: security can’t just live in a silo; it has to be woven into product development, operations, and even business strategy. Perhaps most importantly, we’ve learned that people, processes, and communication strategies are just as important as technology choices.

This shift has raised the bar. It’s no longer sufficient to show that your solution works; you must show how it seamlessly integrates into existing workflows, consider the entire use lifecycle, supports future needs, and gets buy-in across multiple levels of an organization.

The Three Audiences You Need to Win Over

The Technical Champion (80% Tech / 20% Business)

Your security solution will often catch the eye of a deeply technical person first. This might be a security engineer who’s tired of patching the same vulnerabilities or a software architect who sees design flaws that keep repeating. They’re your first and most crucial ally.

Technical champions need more than promises—they need proof. They want detailed demos showing real-world scenarios, sample configurations they can experiment with, and pilot environments where they can test thoroughly. Give them architecture diagrams that satisfy their technical depth, comprehensive documentation that anticipates their questions, and a clear roadmap showing how you’ll address emerging threats and scale for future needs.

Integration concerns keep champions awake at night. They need to understand exactly how your solution will mesh with existing systems, what the deployment strategy looks like, and who owns responsibility for updates and patches. Address their concerns about learning curves head-on with clear documentation and practical migration paths.

While technology drives their interest, champions eventually have to justify their choices to management. Give them a concise one-pager that frames the returns in business terms: reduced incident response time, prevented security gaps, and automated fixes that save precious engineer hours.

Why This Matters:
When you equip your champion with the right resources, they become heroes inside their organizations. They’re the one who discovered that crucial solution before a major breach, who saved the team countless hours of manual work, who saw the strategic threat before anyone else. That kind of impact directly translates to recognition, promotions, and career advancement. The champion who successfully implements a game-changing security solution often becomes the go-to expert, earning both peer respect and management attention. When you help a champion shine like this, they’ll pull your solution along with them as they climb the organizational ladder.

The Economic Buyer (20% Tech / 80% Business)

A passionate champion isn’t always the one holding the purse strings. Often, budget is controlled by directors, VPs, or executives who juggle competing priorities and are measured by overall business outcomes, not technical elegance.

Your buyer needs a concise, compelling story about how this investment reduces risk, saves costs, or positions the company advantageously. Frame everything in terms of bottom-line impact: quantifiable labor hours saved, reduced compliance burdens, and concrete return on investment timelines.

Even without extensive case studies, you can build confidence through hypothetical or pilot data. Paint a clear picture: “Similar environments have seen 30% reduction in incident response time” or “Based on initial testing, we project 40% fewer false positives.” Consider proposing a small pilot or staged rollout—once they see quick wins scaling up becomes an easier sell.

Why This Matters:
When buyers successfully champion a security solution, they transform from budget gatekeepers into strategic leaders in the eyes of executive management. They become known as the one who not only protected the company but showed real business vision. This reputation for combining security insight with business acumen often fast-tracks their career progression. A buyer who can consistently tell compelling business stories—especially about transformative security investments—quickly gets noticed by the C-suite. By helping them achieve these wins, you’re not just securing a deal; you’re empowering their journey to higher organizational levels. And as they advance, they’ll bring your solution with them to every new role and company they touch.

The Broader Market: Present, Teach, and Farm

While winning over individual champions and buyers is crucial, certain security approaches need industry-wide acceptance to truly succeed. Think of encryption standards, identity protocols, and AI based security research tools—these changed the world only after enough people, in multiple communities, embraced them.

Build visibility through consistent conference presentations, industry webinars, and local security meetups. Even with novel technologies, walking people through hypothetical deployments or pilot results builds confidence. Panels and Q&A sessions demonstrate your openness to tough questions and deep understanding of the problems you’re solving.

Make your message easy to spread and digest. While detailed whitepapers have their place, supplement them with short video demonstrations, clear infographics, and focused blog posts that capture your solution’s essence quickly. Sometimes a two-minute video demonstration or one-page technical overview sparks more interest than an extensive document.

Think of education as planting seeds—not every seed sprouts immediately, but consistent knowledge sharing shapes how an entire field thinks about security over time. Engage thoughtfully on social media, address skepticism head-on, and highlight relevant use cases that resonate with industry trends. Consider aligning with open-source projects, industry consortiums, or standards bodies to amplify your reach.

Why This Matters:
By consistently educating and contributing to the community dialogue, you create opportunities for everyone involved to shine. Your champions become recognized thought leaders, speaking at major conferences about their successful implementations. Your buyers get profiled in industry publications for their strategic vision. Your early adopters become the experts everyone else consults. This creates a powerful feedback loop where community advocacy not only drives adoption but establishes reputations and advances careers. The security professionals who help establish new industry norms often find themselves leading the next wave of innovation—and they remember who helped them get there.

Overcoming Common Challenges

The “Not Invented Here” Mindset

Security professionals excel at finding flaws, tearing down systems, and building their own solutions. While this breaker mindset is valuable for discovering vulnerabilities, it can lead to the “Not Invented Here” syndrome: a belief that external solutions can’t possibly be as good as something built in-house.

The key is acknowledging and respecting this culture. Offer ways for teams to test, audit, or customize your solution so it doesn’t feel like an opaque black box. Show them how your dedicated support, updates, and roadmap maintenance can actually free their talent to focus on unique, high-value problems instead of maintaining yet another in-house tool.

Position yourself as a partner rather than a replacement. Your goal isn’t to diminish their expertise—it’s to provide specialized capabilities that complement their strengths. When teams see how your solution lets them focus on strategic priorities instead of routine maintenance, resistance often transforms into enthusiasm.

The Platform vs. Product Dilemma

A common pitfall in security (and tech in general) is trying to build a comprehensive platform before solving a single, specific problem. While platforms can be powerful, they require critical mass and broad ecosystem support to succeed. Many promising solutions have faltered by trying to do too much too soon.

Instead, focus on addressing one pressing need exceptionally well. This approach lets you deliver value quickly and build credibility through concrete wins. Once you’ve proven your worth in a specific area, you can naturally expand into adjacent problems. You might have a grand vision for a security platform, but keep your initial messaging focused on immediate, tangible benefits.

Navigating Cross-Organizational Dependencies

Cross-team dynamics can derail implementations in two common ways: operational questions like “Who will manage the database?” and adoption misalignment where one team (like Compliance) holds the budget while another (like Engineering) must use the solution. Either can stall deals for months.

Design your proof of value (POV) deployments to minimize cross-team dependencies. The faster a champion can demonstrate value without requiring multiple department sign-offs, the better. Start small within a single team’s control, then scale across organizational boundaries as value is proven.

Understand ownership boundaries early: Who handles infrastructure? Deployment? Access control? Incident response? What security and operational checklists must be met for production? Help your champion map these responsibilities to speed implementation and navigate political waters.

The Timing and Budget Challenge

Success often depends on engaging at the right time in the organization’s budgeting cycle. Either align with existing budget line items or engage early enough to help secure new ones through education. Otherwise, your champion may be stuck trying to spend someone else’s budget—a path that rarely succeeds. Remember that budget processes in large organizations can take 6-12 months, so timing your engagement is crucial.

The Production Readiness Gap

A signed deal isn’t the finish line—it’s where the real work begins. Without successful production deployment, you won’t get renewals and often can’t recognize revenue. Know your readiness for the scale requirements of target customers before engaging deeply in sales.

Be honest about your production readiness. Can you handle their volume? Meet their SLAs? Support their compliance requirements? Have you tested at similar scale? If not, you risk burning valuable market trust and champion relationships. Sometimes the best strategy is declining opportunities until you’re truly ready for that tier of customer.

Having a clear path from POV to production is critical. Document your readiness criteria, reference architectures, and scaling capabilities. Help champions understand and navigate the journey from pilot to full deployment. Remember: a successful small customer in production is often more valuable than a large customer stuck in pilot or never deploys into production and does not renew.

Overcoming Entrenched Solutions

One of the toughest challenges isn’t technical—it’s navigating around those whose roles are built on maintaining the status quo. Even when existing solutions have clear gaps (like secrets being unprotected 99% of their lifecycle), the facts often don’t matter because someone’s job security depends on not acknowledging them.

This requires a careful balance. Rather than directly challenging the current approach, focus on complementing and expanding their security coverage. Position your solution as helping them achieve their broader mission of protecting the organization, not replacing their existing responsibilities. Show how they can evolve their role alongside your solution, becoming the champion of a more comprehensive security strategy rather than just maintaining the current tools.

Putting It All Together

After three decades in security, one insight stands out: success depends as much on communication as on code. You might have the most innovative approach, the sleekest dashboard, or a bulletproof protocol—but if nobody can articulate its value to decision-makers and colleagues, it might remain stuck at the proof-of-concept stage or sitting on a shelf.

Your technical champion needs robust materials and sufficient business context to advocate internally. Your economic buyer needs clear, ROI-focused narratives supported by concrete outcomes. And the broader market needs consistent education through various channels to understand and embrace new approaches.

Stay mindful of cultural barriers like “Not Invented Here” and resist the urge to solve everything at once. Focus on practical use cases, maintain consistent messaging across audiences, and show how each stakeholder personally benefits from your solution. This transforms curiosity into momentum, driving not just adoption but industry evolution.

Take a moment to assess your approach: Have you given your champion everything needed to succeed—technical depth, migration guidance, and business context? Does your buyer have a compelling, ROI-focused pitch built on solid data? Are you effectively sharing your story with the broader market through multiple channels?

If you’re missing any of these elements, now is the time to refine your strategy. By engaging these three audiences effectively, addressing cultural barriers directly, and maintaining focus on tangible problems, you’ll help advance security one success story at a time.

The Account Recovery Problem and How Government Standards Might Actually Fix It

Account recovery is where authentication systems go to die. We build sophisticated authentication using FIDO2, WebAuthn, and passkeys, then use “click this email link to reset” when something goes wrong. Or if we are an enterprise, we spend millions staffing help desks to verify identity through caller ID and security questions that barely worked in 2005.

This contradiction runs deep in digital identity. Organizations that require hardware tokens and biometrics for login will happily reset accounts based on a hope and a prayer. These companies that spend fortunes on authentication will rely on “mother’s maiden name” or a text message of a “magic number” for recovery. Increasingly we’ve got bank-vault front doors with screen-door back entrances.

The Government Solution

But there’s an interesting solution emerging from an unexpected place: government identity standards. Not because governments are suddenly great at technology, but because they’ve been quietly solving something harder than technology – how to agree on how to verify identity across borders and jurisdictions.

The European Union is pushing ahead with cross-border digital identity wallets based on their own standards. At the same time, a growing number of U.S. states—early adopters like California, Arizona, Colorado, and Utah—are piloting and implementing mobile driver’s licenses (mDLs). These mDLs aren’t just apps showing a photo ID; they’re essentially virtual smart cards, containing a “certificate” of sorts that is used to attest to certain information about you, similar to what happens with electronic reading of passports and federal CAC cards. Each of these mDL “certificates” are cryptographically traceable back to the issuing authority’s root of trust, creating verifiable chains of who is attesting to these attributes.

One of the companies helping make this happen is SpruceID, a company I advise. They have been doing the heavy lifting to enable governments and commercial agencies to accomplish these scenarios, paving the way for a more robust and secure digital identity ecosystem.

Modern Threats and Solutions

What makes this particularly relevant in 2024 is how it addresses emerging threats. Traditional remote identity verification relies heavily on liveness detection – systems looking at blink patterns, reflections and asking users to turn their heads, or show some other directed motion. But with generative AI advancing rapidly, these methods are becoming increasingly unreliable. Bad actors can now use AI to generate convincing video responses that fool traditional liveness checks. We’re seeing sophisticated attacks that can mimic these patterns the existing systems look at, even the more nuanced subtle facial expressions that once served as reliable markers of human presence.

mDL verification takes a fundamentally different approach. Instead of just checking if a face moves correctly, it verifies cryptographic proofs that link back to government identity infrastructure. Even if an attacker can generate a perfect deepfake video, they can’t forge the cryptographic attestations that come with a legitimate mDL. It’s the difference between checking if someone looks real and verifying they possess cryptographic proof of their identity.

Applications and Implementation

This matters for authentication because it gives us something we’ve never had: a way to reliably verify legal identity during account authentication or recovery that’s backed by the same processes used for official documents. This means that in the future when someone needs to recover account access, they can prove their identity using government-issued credentials that can be cryptographically verified, even in a world where deepfakes are becoming indistinguishable from reality.

The financial sector is already moving on this. Banks are starting to look at how they can integrate mDL verification into their KYC and AML compliance processes. Instead of manual document checks or easily-spoofed video verification, they will be able to use these to verify customer identity against government infrastructure. The same approaches that let customs agents verify passports electronically will now also be used to enable banks to verify customers.

For high-value transactions, this creates new possibilities. When someone signs a major contract, their mDL can be used to create a derived credential based on the attestations from the mDL about their name, age, and other artifacts. This derived credential could be an X.509 certificate binding their legal identity to the signature. This creates a provable link between the signer’s government-verified identity and the document – something that’s been remarkably hard to achieve digitally.

Technical Framework

The exciting thing isn’t the digital ID – they have been around a while – it’s the support for an online presentment protocol. ISO/IEC TS 18013-7 doesn’t just specify how to make digital IDs; it defines how these credentials can be reliably presented and verified online. This is crucial because remote verification has always been the Achilles’ heel of identity systems. How do you know someone isn’t just showing you a video or a photo of a fake ID? The standard addresses these challenges through a combination of cryptographic proofs and real-time challenge-response protocols that are resistant to replay attacks and deep fakes.

Government benefits show another critical use case. Benefits systems face a dual challenge: preventing fraud while ensuring legitimate access. mDL verification lets agencies validate both identity and residency through cryptographically signed government credentials. The same approach that proves your identity for a passport electronically at the TSA can prove your eligibility for benefits online. But unlike physical ID checks or basic document uploads, these verifications are resistant to the kind of sophisticated fraud we’re seeing with AI-generated documents and deepfake videos.

What’s more, major browsers are beginning to implement these standards as a first-class citizen. This means that verification of these digital equivalents of our physical identities  will be natively supported by the web, ensuring that online interactions—from logging in to account recovery—are more easier and more secure than ever before.

Privacy and Future Applications

These mDLs have interesting privacy properties too. The standards support selective disclosure – proving you’re over 21 without showing your birth date, or verifying residency without exposing your address. You can’t do that with a physical ID card. More importantly, these privacy features work remotely – you can prove specific attributes about yourself online without exposing unnecessary personal information or risking your entire identity being captured and replayed by attackers.

We’re going to see this play out in sensitive scenarios like estate access. Imagine a case when someone needs to access a deceased partner’s accounts, they can prove their identity and when combined with other documents like marriage certificates and death certificates, they will be able to prove their entitlement to access that bank account without the overhead and complexity they need today. Some day we can even imagine those supporting documents to be in these wallets also, making it even easier.

The Path Forward

While the path from here to there is long and there are a lot of hurdles to get over, we are clearly on a path where this does happen. We will have standardized, government-backed identity verification that works across borders and jurisdictions. Not by replacing existing authentication systems, but by providing them with a stronger foundation for identity verification and recovery and remote identity verification – one that works even as AI makes traditional verification methods increasingly unreliable.

We’re moving from a world of island of identity systems to one with standardized and federated identity infrastructure, built on the same trust frameworks that back our most important physical credentials. And ironically, at least in the US it started with making driver’s licenses digital.

What Makes a QR Code Verifiable?

QR codes are everywhere—tickets, ID cards, product packaging, menus, and even Wi-Fi setups. They’ve become a cornerstone of convenience, and most of us scan them without hesitation. But here’s the thing: most QR codes aren’t cryptographically signed. In practice, this means we’re trusting their contents without any way to confirm they’re authentic or haven’t been tampered with.

One reason QR codes are so useful is their data density. They can store much more information than simpler formats like barcodes, making them ideal for embedding cryptographic metadata, references, or signatures while remaining scannable. However, QR codes have size limits, which means the cryptographic overhead for signing needs to be carefully managed to maintain usability.

While unauthenticated QR codes are fine for low-stakes uses like menus, relying on them for sensitive applications introduces risk. Verifiable QR codes use cryptographic signatures to add trust and security, ensuring authenticity and integrity—even in a post-quantum future.

How Are Verifiable QR Codes Different?

The key difference lies in cryptographic signatures. Verifiable QR codes use them to achieve two things:

  • Authentication: They prove the QR code was generated by a specific, identifiable source.
  • Integrity: They ensure the data in the QR code hasn’t been altered after its creation.

This makes verifiable QR codes especially useful in scenarios where trust is critical. For instance, an ID card might contain a QR code with a cryptographic signature over its MRZ (Machine Readable Zone). If someone tampers with the MRZ, the signature becomes invalid, making forgery far more difficult.

Why Think About Post-Quantum Security Now?

Many systems already use signed QR codes for ticketing, identity verification, or supply chain tracking. However, these systems often rely on classical cryptographic algorithms like RSA or ECDSA, which are vulnerable to quantum attacks. Once quantum computers become practical, they could break these signatures, leaving QR codes open to forgery.

That’s where post-quantum cryptography (PQC) comes in. PQC algorithms are designed to resist quantum attacks, ensuring the systems we rely on today remain secure in the future. For QR codes, where size constraints matter, algorithms like UOV and SQISign are especially promising. While most standardized PQC algorithms (like CRYSTALS-Dilithium or Falcon) produce relatively large signatures, UOV and SQISign aim to reduce signature sizes significantly. This makes them better suited for QR codes, which have limited space to accommodate cryptographic overhead.

By adopting post-quantum signatures, verifiable QR codes can address today’s security needs while ensuring long-term resilience in a post-quantum world.

What’s Practical in Implementation?

For verifiable QR codes to work at scale, standard formats and easy-to-use verifiers are essential. Ideally, your smartphone’s default camera should handle verification without requiring extra apps, potentially deep-linking into installed applications. This kind of seamless integration is crucial for widespread adoption.

Verifiable QR codes don’t need to include all the data they validate. Instead, they can store a reference, an identifier, and a cryptographic signature. This approach stays within QR code size limits, accommodating cryptographic overhead while keeping the codes lightweight and usable.

Think of verifiable QR codes as digital certificates. They tie the QR code’s contents back to an issuer within a specific ecosystem, whether it’s a ticketing platform, a supply chain, or an identity system. To build transparency and trust, these signatures could even be logged in a transparency log (tlog), much like Certificate Transparency for web certificates. This would make the issuance of QR codes auditable, ensuring not only the validity of the signature but also when and by whom it was issued.

What About Purely Digital Use Cases?

Even without a physical object like a driver’s license, verifiable QR codes offer significant value. For instance, an online ticket or access pass can prove its issuer and verify its contents with contactless reading. Key benefits include:

  • Confirming the QR code came from a legitimate issuer (e.g., a trusted ticketing platform).
  • Ensuring the content hasn’t been altered, reducing phishing or tampering risks.

This assurance is especially critical in digital-only contexts where physical cross-checking isn’t an option, or additional information is needed to verify the object.

Where Verifiable QR Codes Shine

  • URL-Based QR Codes: Phishing is a growing problem, and QR codes are often used as bait. A verifiable QR code could cryptographically confirm a URL matches its intended domain, letting users know it’s safe before they click—a game-changer for consumers and enterprises.
  • Identity and Credentials: Driver’s licenses or passports could include QR codes cryptographically tied to their data. Any tampering, digital or physical, would break the signature, making counterfeits easier to detect.
  • Event Tickets: Ticket fraud costs billions annually. Verifiable QR codes could tie tickets to their issuing authority, allowing limited offline validation while confirming authenticity.
  • Supply Chain Security: Counterfeiting plagues industries like pharmaceuticals and luxury goods. Signed QR codes on packaging could instantly verify product authenticity without needing centralized databases.
  • Digital Proof of Vaccination: During the COVID-19 pandemic, QR codes became a common way to share vaccination records. A verifiable QR code would tie the data to an official source, simplifying verification while reducing counterfeit risks at borders, workplaces, or events.

Enhancing Trust in Everyday Interactions

Verifiable QR codes bridge the gap between convenience and trust. By incorporating cryptographic signatures—especially post-quantum ones—they add a necessary layer of security in an increasingly digital world.

While they won’t solve every problem, verifiable QR codes offer a practical way to improve the reliability of systems we already depend on. From verifying tickets and vaccination records to securing supply chains, they provide a scalable and effective solution for building trust into everyday interactions. As verification tools integrate further into devices and platforms, verifiable QR codes could become a cornerstone of authenticity in both physical and digital spaces.

Beyond the Facade: Evaluating Long-Term Impacts of Enterprise Software Architectures

Many enterprise products these days have a core architecture that consists of placing a proxy in front of an existing service. While the facade architecture makes sense in some cases, it’s usually a temporary measure because it increases the costs of administration, scaling, security, and debugging. It also adds complexity to general management.

The use cases for these offerings often involve one team in an organization providing incremental value to a service operated by another team. This introduces various organizational politics, which make anything more than a proof of concept not really viable, at least on an ongoing basis.

Essentially, anyone who has ever carried a pager or tried to deploy even the most basic system in a large enterprise should avoid this pattern except as a stopgap solution for a critical business system. It is far better, in the medium and long term, to look at replacing the fronted system with something that provides the needed integration or capability natively.

For example, some solutions aim to enable existing systems to use quantum-secure algorithms. In practice, these solutions often look like a single TLS server sitting in front of another TLS server, or a TLS-based VPN where a TLS client (for example, integrating via SOCKS) interfaces with your existing TLS client, which then communicates with that TLS server sitting in front of another TLS server. You can, of course, implement this, and there are places where it makes sense. However, on a long-term basis, you would be better off if there were native support for quantum-secure algorithms or switching out the legacy system altogether.

Similarly, it’s very common now for these enterprise-focused solutions to split the architecture between on-premise/private cloud and a SaaS component. This approach has several benefits: the on-premise part enables integration, core policy enforcement, and transaction handling, and, if done right, ensures availability. The SaaS component serves as the control plane. This combination gives you the best benefits of both on-premise and SaaS offerings and can be implemented while minimizing the security impact of the service provider.

Another pattern that might be confused with this model is one where transactional policy enforcement or transaction handling happens in the SaaS part of the solution, while the integration element remains on-premise. This is probably the easiest to deploy, so it goes smoothly in a proof of concept. However, it makes the SaaS component mission-critical, a performance bottleneck, and a single point of failure, while also pulling it entirely into the threat model of the component. There are cases where this model can work, but for any system that needs to scale and be highly reliable, it’s often not the best choice.

These architectural decisions in third-party solutions have other large impacts that need to be considered, such as data residency and compliance. These are especially important topics outside the US but are also issues within the US if you handle sensitive data and work in regulated markets. Beyond that, architecture and design choices of third-party products can have vendor lock-in consequences. For example, if the solution is not based on open standards, you may find yourself in an inescapable situation down the road without a forklift upgrade, which is often not viable organizationally if the solution fails to deliver.

So why does all of this matter? When we evaluate the purchase of enterprise security software, we need to be sure to look beyond the surface, beyond the ingredient list, and understand how the system is built and how those design decisions will impact our security, availability, performance, maintainability and total cost of ownership both in the near term and long term. Enterprise architects and decision-makers should carefully consider these factors when evaluating different architectural patterns.

ACME vs. SPIFFE: Choosing the Right One

In the world of certificate lifecycle management for workloads, two approaches often come into focus: ACME (Automated Certificate Management Environment) and SPIFFE (Secure Production Identity Framework for Everyone). While both can deliver certificates to a device or workload, they cater to different use cases. Let’s explore their core differences and why these matter, especially for dynamic workload deployments.

ACME: Proving Control Over Identifiers

ACME is primarily designed to prove control over an identifier, typically a domain name, and to deliver a certificate that demonstrates successful control verification.

  • Control Verification: ACME verifies control through various methods such as HTTP-01, DNS-01, TLS-ALPN, and External Account Binding.
  • Attestation (Optional): Attestation in ACME is secondary and optional, primarily enabling verifying if the key is well protected.
  • Pre-assigned Identifiers: ACME assumes that the identifier (like a domain name) is pre-assigned and focuses on validating control over this identifier.

This approach is particularly useful for scenarios where identifiers are static and pre-assigned, making it ideal for server authenticated TLS and applications that rely on domain names.

SPIFFE: Dynamic Assignment of Identifier Based on Attestation

SPIFFE, conversely, is designed for dynamic workloads, which frequently change as services scale or update. SPIFFE assigns identifiers to workloads dynamically, based on attestation.

  • Identifier Assignment: SPIFFE assigns an identifier to the subject (such as a workload) using attestation about the subject to construct this identifier.
  • Attestation: Unlike ACME, attestation is a core component in SPIFFE, enabling robust multi-factor authentication (MFA) for workloads based on what is running and where it is running.
  • Namespacing and Least Privilege: SPIFFE facilitates the namespacing of identifiers, building a foundation that enables authorization frameworks that promote least privilege, ensuring workloads only access necessary resources.
  • Minimal Security Domains: At the core of SPIFFE is the concept of security domains, which serve as trust boundaries between services, helping to minimize the attack surface.
  • JWT and X.509: SPIFFE supports SVIDs in both X.509 and JWT formats, enabling seamless integration with various systems and protocols within cloud deployments.

Importance in Dynamic Workload Deployments

The differences between ACME and SPIFFE are particularly significant in dynamic workload deployments:

  • Flexibility and Scalability: SPIFFE’s dynamic identifier assignment is highly suitable for environments where workloads are frequently spun up and down, such as in microservices architectures and Kubernetes clusters.
  • Role-Based Authentication: By making attestation a core component and promoting least privilege, SPIFFE ensures that each workload is authenticated and authorized precisely for its intended role.
  • Granular Policy Enforcement: SPIFFE’s namespacing and minimal security domain features enable fine-grained policy enforcement, enabling organizations to define and enforce policies at a more granular level, such as per-workload or per-service.
  • Identity Federation: SPIFFE supports identity federation enabling different trust domains to interoperate securely. This is particularly beneficial in multi-cloud and hybrid environments where different parts of an organization or third-parties.

Conclusion

While both ACME and SPIFFE are used for certificate management, they cater to different scenarios and can complement each other effectively. ACME is ideal for static environments where identifiers are pre-allocated, focusing on certificate lifecycle management for issuing, renewing, and revoking certificates. It excels in managing the lifecycle of certificates for web servers and other relatively static resources. 

On the other hand, SPIFFE excels in dynamic, high-scale environments, emphasizing credential lifecycle management with flexible and robust authentication and authorization through dynamic identifiers and attestation. SPIFFE is designed for modern, cloud-native architectures where workloads are ephemeral, and identifiers need to be dynamically issued and managed. 

By understanding these differences, you can leverage both ACME and SPIFFE to enhance your identity management strategy. Use ACME for managing certificates in static environments to ensure efficient lifecycle management. Deploy SPIFFE for dynamic environments to provide strong, attested identities for your workloads.

Gov ID: If at First You Don’t Succeed, Try, Try Again

In the eIDAS 2.0 framework, the identity wallet is central to its expanded scope, mirroring early European government efforts at smart card-based national identity cards as well as subsequent identity wallet attempts. These efforts saw limited adoption, except for a few cases such as the Estonian national identity card,  the Swedish e-identification, and the Dutch eID schemes. It seems that this part of eIDAS 2.0 is an effort to blend the best aspects of these projects with elements of Web3 in an attempt to achieve a uniform solution.

A significant shift from these past identity wallet efforts is the government’s role in identity verification, reminiscent of the earlier smart card national ID initiatives. This approach diverges from the prior identity wallet models, where external entities such as banks, telecoms, and commercial identity verification companies were responsible for verification. This combination potentially helps pave the way for holistic public sector adoption similar to what was seen with Estonia’s national ID project’s success just on a much larger scale.

With that said it is important to remember that the majority of past efforts have struggled to achieve broad adoption. For example, the GOV.UK Verify platform encountered substantial usability issues, leading to resistance and eventually discontinued use by organizations that were mandated to use it. While the software-based nature of identity wallets may reduce deployment costs relative to smart cards, and government mandates could kick-start some level of adoption, the challenge of achieving widespread acceptance does not go away.

As it stands, it does seem that European CAs are betting on this to bootstrap a larger market for themselves. However, in a system as described above, this raises questions about the broader value and future role of third-party trust providers especially in a world where HTTPS on the web is protected with domain-validated certificates that these CAs have largely ignored or resisted.

This brings us to the contentious issue of the eIDAS 2.0 framework’s push for Qualified Web Authentication Certificates (QWACs) and the enforced support by browsers. While it is tempting to look at these two parts of the effort in isolation it is important to remember that regulations like these are made up of horse trading, so it is not surprising to see how clumsily this has all progressed. 

As an aside if you have not seen it there was an interesting talk at Chaos Computer Club last month about how badly these identity schemes have been executed that is worth watching. Only time will tell how effectively eIDAS 2.0 navigates these challenges and whether it can achieve the broad adoption that has eluded past initiatives.

Effortless Certificate Lifecycle Management for S/MIME

In September 2023, the SMIME Baseline Requirements (BRs) officially became a requirement for Certificate Authorities (CAs) issuing S/MIME certificates (for more details, visit CA/Browser Forum S/MIME BRs).

The definition of these BRs served two main purposes. Firstly, they established a standard profile for CAs to follow when issuing S/MIME certificates. Secondly, they detailed the necessary steps for validating each certificate, ensuring a consistent level of validation was performed by each CA.

One of the new validation methods introduced permits mail server operators to verify a user’s control over their mailbox. Considering that these services have ownership and control over the email addresses, it seems only logical for them to be able to do domain control verification on behalf of their users since they could bypass any individual domain control challenge anyway. This approach resembles the HTTP-01 validation used in ACME (RFC 8555), where the server effectively ‘stands in’ for the user, just as a website does for its domain.

Another new validation method involves delegating the verification of email addresses through domain control, using any approved TLS domain control methods. Though all domain control methods are allowed for in TLS certificates as supported its easiest to think of the DNS-01 method in ACME here. Again the idea here is straightforward: if someone can modify a domain’s TXT record, they can also change MX records or other DNS settings. So, giving them this authority suggests they should reasonably be able to handle certificate issuance.

Note: If you have concerns about these two realities, it’s a good idea to take a few steps. First, ensure that you trust everyone who administers your DNS and make sure it is securely locked down. 

To control the issuance of S/MIME certificates and prevent unauthorized issuance, the Certification Authority Authorization (CAA) record can be used. Originally developed for TLS, its recently been enhanced to include S/MIME (Read more about CAA and S/MIME).

Here’s how you can create a CAA record for S/MIME: Suppose an organization, let’s call it ‘ExampleCo’, decides to permit only a specific CA, ‘ExampleCA’, to issue S/MIME certificates for its domain ‘example.com’. The CAA record in their DNS would look like this:

example.com. IN CAA 0 smimeemail "ExampleCA.com"

This configuration ensures that only ‘ExampleCA.com’ can issue S/MIME certificates for ‘example.com’, significantly bolstering the organization’s digital security.

If you wanted to stop any CA from issuing a S/MIME certificate you would create a record that looks like this: 

example.com. IN CAA 0 issuemail ";"

Another new concept introduced in this round of changes is a new concept called an account identifier in the latest CAA specification. This feature allows a CA to link the authorization to issue certificates to a specific account within their system. For instance:

example.com. IN CAA 0 issue "ca-example.com; account=12345"

This means that ‘ca-example.com’ can issue certificates for ‘example.com’, but only under the account number 12345.

This opens up interesting possibilities, such as delegating certificate management for S/MIME or CDNs to third parties. Imagine a scenario where a browser plugin, is produced and managed by a SaaS on behalf of the organization deploying S/MIME. This plug-in takes care of the initial enrollment, certificate lifecycle management, and S/MIME implementation acting as a sort of S/MIME CDN.

This new capability, merging third-party delegation with specific account control, was not feasible until now. It represents a new way for organizations to outsource the acquisition and management of S/MIME certificates, simplifying processes for both end-users and the organizations themselves.

To the best of my knowledge, no one is using this approach yet, and although there is no requirement yet to enforce CAA for SMIME it is in the works. Regardless the RFC has been standardized for a few months now but despite that, I bet that CAs that were issuing S/MIME certificates before this new CAA RFC was released are not respecting the CAA record yet even though they should be. If you are a security researcher and have spare time that’s probably a worthwhile area to poke around 😉

Document Authenticity in the Age of Generative AI

In our rapidly evolving lives, the credibility of documents, images, and videos online has emerged as a concern. The pandemic and recent elections have helped highlight this issue. In the case of elections, one area that stands out to me is concerns over voter roll integrity, a pillar of our democratic process in the US.  

As we grapple with these issues, it is important to explore what a solution might look like that balances the associated privacy concerns. Is it possible to provide assurance of integrity and transparency while also providing accommodations for privacy and accountability?

Misinformation in the Digital Age

Despite its challenges, the pandemic did have a silver lining — it brought attention to the internet’s role as a breeding ground for misinformation campaigns. These campaigns featured manipulated images and documents, creating confusion and distrust globally. They also underscored a glaring gap in our current systems — no broad deployment of reliable mechanisms to verify the authenticity and origin of digital content.

The recent advancements in generative AI over the last two years have further complicated this issue. Now with a few words, anyone on the web can create images that at first blush look real. This technology will only continue to get better which means we will need to begin to more formally look at how we build solutions to tackle this new reality.

Existing Solutions and Their Shortcomings

Several technologies have recently been discussed as the way forward to address at least portions of these problems. One such example is the Content Authenticity Initiative which proposes that devices like cameras cryptographically sign all pictures and videos with a device credential, a feature aimed at enabling the detection of any alterations made post-capture. 

This method raises significant privacy concerns. Essentially, it could create a surveillance infrastructure where each content piece could be unexpectedly traced back to an individual or a group of devices, potentially becoming a surveillance tool.

Google DeepMind also recently brought forth the idea of opt-in watermarking for images created through AI technologies. While this initiative seems promising at a glance, it fails to address the nuances of the threat model. For instance, a nation-state with intentions to manipulate an election using generative AI assets wouldn’t likely volunteer to watermark these materials as AI-generated. This significant loophole sets a precarious stage where misinformation can still flourish.

These approaches, though developed with noble intentions, reveal critical gaps in addressing the complex landscape of content authenticity. They either infringe upon individual privacy rights or are vulnerable to exploitation when faced with a real threat model. 

Middle Ground: Publisher Signatures and Blinding as a Potential Solution

A more nuanced approach could utilize optional cryptographic signatures linked to a publisher, instead of devices, when signed, the publisher, not their devices, opts into staking their reputation on the authenticity of the artifact. Coupled with a feature to enable cryptographically blinding the publisher’s identity, this strategy could offer a safe avenue for them to reveal their identity at a later time, if necessary. Such a situation might arise in cases of whistleblower claims, where shielding the publisher’s identity becomes crucial for their safety. This blinding could strike a balance, granting publishers temporary anonymity while preserving the potential to enable them to later opt-in to publicly stand behind the artifact or to take accountability for any misinformation.

In contrast to devices subtly leaking metadata that would put subjects in the position to have to prove a negative, for example, needing to explain a picture does not tell the whole story. Or even worse putting the subject of a picture in a situation where they need to prove that the device that captured it was compromised, This is similar to what happens today with red-light cameras and automated radar guns where poorly calibrated devices result in innocent people being charged.

The proposed model shifts the identification to publishers in the hope of fostering a responsible publishing culture where publishers have the discretion to unveil their identity, promoting accountability without completely compromising privacy.

It is also worth noting that a transition from ink signatures to cryptographic signatures for documents appears more pertinent than ever. Generative AI and graphic design technologies have enhanced the ability to replicate handwriting styles, making traditional signatures highly susceptible to forgery. The use of cryptographic techniques offers a more secure alternative, integrating seamlessly into modern workflows and standing resilient against unauthorized alterations.

Publisher Signatures Are Not Enough

In information security, it’s now accepted that insider threats are a significant risk. This realization has steered us away from merely verifying the identity of a publisher, especially in cryptographic signing systems such as code signing. 

There are a few reasons, but one of the largest is that key management proves to be challenging, often due to the fact that publishers frequently represent groups rather than individuals, leading to key management practices being more permissive than ideal from a security standpoint. 

Additionally, if a solution is to incorporate the possibility of anonymity through cryptographic blinding we can not simply bet on the presence and blind trust in that identity.

This is the same reason that led modern code-signing solutions to adopt ledgers that record an artifact’s provenance and history. For instance, in a Binary Transparency system, a ledger might house not only a list of software packages and their contents but also offer qualitative attestations about the software, for example indicating whether it has been screened for malware or verified to be reproducible from its source. This mechanism allows devices to understand not just the origin of the code but also to grasp the intended release of the software and potentially qualitative aspects to consider before reliance on it.

Applying this pattern to our document provenance and integrity problem, this system can offer value even when the identity remains undisclosed. It can provide a basic idea of the time of existence and allow third parties to vouch for the authenticity, possibly linking to other corroborative artifacts.

Building a continuously verifiable record coupled with supportive evidence for artifacts like documents seems to be a step in the right direction. This approach has demonstrated its value in other problem spaces.

With that said it’s essential to acknowledge that, as with any opt-in system, documents, images, and videos will not all contain this additional provenance and like with all technology this too would not be perfect. As a result, this means that rather than outright dismissal, all content will need to be evaluated based on merit, and the evidence collected about it. At a minimum, we must recognize that it can take years for any new system to gain substantial traction.

Learning from the rest of the world.

This issue is not confined to the US, so we should not restrict ourselves to looking at approaches used by US Big Tech. For instance, the strategies suggested here significantly draw upon the principles of electronic signatures, particularly e-Seals, which are prevalent in the EU and other regions. This European model offers vital insights and presents a robust strategy for resolving disputes, albeit reliant on specific technologies.

Interestingly, US online notarization rules have also borrowed elements from the EU, mandating the use of cryptographic signatures, akin to the EU’s emphasis on Advanced Signatures.

By combining this approach with the lessons learned from Certificate and Binary Transparency, where Merkle trees of published materials, continuous monitoring, and third-party evaluation help ensure a more complete picture — we might find a path forward. 

The addition of blinding the publisher’s identity in a way where they could selectively disclose their identity in the future also seems to provide a plausible way to balance the privacy concerns that could enable this path to become the default in the future.

Motivating Participation through Innovation, Policy and Leadership

Adoption of this approach cannot solely rely on goodwill or regulation. It would require a combination of standardization, regulatory changes, creating incentives for publishers, engagement with civil society and other stakeholders, and some tangible leadership by example by a large player or two. Some ideas in this direction include:

  • Initiating revisions to the existing digital signature legislation seems to be a sensible first step. Given our substantial background with the current laws, it’s clear that without regulatory changes, technological investments are unlikely to shift.
  • The government can lead by example by enhancing initiatives like the current Digital Autopen project. This project allows groups of individuals to access shared signing credentials without tying them to individual users, addressing a notable challenge prevalent in code signing and other organizational signing efforts.
  • I also believe that investing in a singular, immensely impactful use case as a case study could vividly illustrate how these approaches can make a significant difference. The voter registration rolls mentioned earlier seem like an excellent use case for this.
  • Further research and standardization could explore integrating cryptographic blinding of signer identities within the current document signing infrastructure, allowing for future disclosure. Investigating the potential structure and security of ledgers, and considering the extension of signing protocols to other artifact formats, seems to be a natural progression in supporting a system of this kind.
  • Simultaneously, collaboration with civil society, tech companies, and other stakeholders, including publishers, appears vital. This will guarantee that their concerns are integrated into the developed solutions and that appropriate policies are instituted to effectively incorporate this metadata into their operations.
  • I also believe investing in a singular and hugely impactful use case as a case study of how these approaches can make a big difference. The voter registration rolls discussed earlier seem like a great use case for this.

While these efforts would not necessarily lead to adoption it does seem that adoption would minimally be a predicate on efforts like these.

A Pathway to Trust and Accountability

Balancing privacy and accountability in the digital age is a nuanced but achievable goal, especially if we build on top of existing successes. By adopting a well-rounded approach that integrates cryptographic signatures with mechanisms for temporary anonymity, we can carve a pathway toward a society where digital content maintains its integrity and trustworthiness. 

Moreover, by fostering an environment where content, even without clear provenance, is evaluated critically rather than dismissed, we encourage a richer discourse and a healthier digital ecosystem.

Through the union of technology and policy, we can create a more secure, transparent, and accountable future for content authenticity.

How is ACME different than XCEP/WSTEP anyway?

If you read my blog there is a reasonable chance that you are familiar with RFC 8555, the standard for Automatic Certificate Management Environment (ACME). Even though ACME is a relatively young protocol it is already used by the majority of websites on the internet for certificate lifecycle management.

While I won’t go into a lot of detail for this post to make sense you have to understand a couple of things about the ACME protocol. 

The first is that it works on the concept of dynamic “account” registration. By that I mean requestors can in real-time, request that an “account” be created for them. This account is represented by a public key pair that the ACME service will use to persist meta-data about the requestor. The ACME service can deny this request for any reason it likes but commonly in Web PKI as long as the request is wellformed it is accepted.

The next thing you need to understand is that it has the concept of “challenges” that can be used to communicate conditions that must be met before a certificate is issued. For example, an ACME service may request that the account holder demonstrate that they are authorized to get a certificate for a given domain name by placing a specific value in DNS at a well-known location. Since only a DNS administrator could perform that action the ACME service can have confidence the requestor controls the name it has requested a certificate for.

And finally, there is nothing in the ACME protocol that limits its use to just web server certificates. It is a general framework that can be used to acquire and manage certificates of any type. For example, CISCO is using ACME in their WebEx offering to facilitate the acquisition of what are essentially email certificates via OIDC authentication as a way to authenticate chat members.

But there is another very popular protocol, a well set of protocols that fewer people know about, that is XCEP and WSTEP. These protocols are used by Windows machines to both determine what kind of certificates a machine or user should enroll for as well as enabling the enrollment for those certificates. 

Similar to ACME these protocols also support, although in a more ridged rigid way, the ability for the issuer to challenge the client for additional information necessary to get a certificate of a particular type. For example, you can configure a certificate type (known as a template) to require that the requestor provide a cryptographic attestation backed by a TPM to be used to prove the machine belongs to the organization operating the certificate authority.

There are differences though, the first of which is the concept of a template, this enables XCEP/WSTEP to have one URL endpoint issue many types of certificates which is very important within an enterprise which is where certificates are used for many different scenarios.

Another difference is that XCEP/WSTEP presume the authorization of the client happened out of the band before the client requested the certificate. The dynamic approach to challenges that was adopted by ACME allowed it to tackle this problem in-band or rely on the out-of-band authorization. It supports this out-of-band concept through the concept of External Account Binding which allows the requestor to use an API key gathered out of band to prove on account creation the account key is associated with some pre-enrolled user.

And finally, ACME has a clear model for extensibility built into it. What this means is that one can easily extend it with additional capabilities. The most fundamental part of this is the Directory resource which lists all of the APIs supported by this ACME instance. One could use this, for example, to add a “Templates” API that would allow an ACME client to request specific types of certificates from the ACME endpoint.

Similarly, the concept of the challenge allows the server to demand the client do any number of things before the certificate is to be issued so the idea of adding a TPM challenge, for example, is trivial within this framework.

In short, ACME, contrary to popular belief, is not a protocol for getting and managing website certificates it is a framework for getting and managing any certificate. More importantly, it is extensible in such a way that with just a few minor additions it would be a proper superset of all the capabilities within the Windows enrollment protocol suite.

Why is this important? That’s easy! When I talk to anyone who is using certificates at any reasonable scale their concerns almost instantly come to the complexity of managing the certificate lifecycle management of those certificates across the various products and services that use them.

When we look at this complexity most of it arises from the use of a mish-mash of solutions for lifecycle management that when viewed in isolation seemed sufficient but when looked at holistically were actually woefully insufficient. 

If as an industry we move these legacy systems to a single protocol so that certificates regardless of them being for public or private PKI or representing users, machines or workloads use one protocol we will have a reliable substrate that we can use to authenticate and authorize with agility.