Let's Encrypt bans certificate usage in any US sanctioned territory [pdf]

208 pointsposted a day ago
by piskov

155 Comments

CobrastanJorji

2 hours ago

Let's Encrypt’s mission is to create a more secure and privacy-respecting web, except for people residing in countries with the most need for a more secure and privacy-respecting web. Sure, that's great.

That said, pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries. I'm sure some of y'all are old enough to remember when web browsers came in "international friendly" versions that supported 40 bit encryption, or "fancy secure" versions with 128 bit encryption.

rzerowan

2 hours ago

Seems in all thing tech at the moment the US legal system is accelearting a great split and erectinga digital iron curtain, from AI models to the more mundane like TLS certs. Its been standard for a while for many Linux distros based in the US to toe the party line - like RedHat having notices pretty similar to this one by LE. Seems any meaningful Open Projects will have to choose what path they want to take, be like RISC-V and relocate or LE and others and enforce the divide.

xxpor

39 minutes ago

The RISC-V move was laughable. It’s still US tech, developed largely with DARPA funds.

throwaway85825

4 minutes ago

If you truly need a secure and private web you should be using tor.

idoubtit

14 hours ago

Couldn't LE have a branch in Europe or anywhere outside the USA and its minions?

Because they're betraying their own goals, as stated in their About page: “It is a service run for the public’s benefit. [...] Anyone who owns a domain name can use Let’s Encrypt to obtain a trusted certificate at zero cost. [...] Let’s Encrypt is a joint effort to benefit the community, beyond the control of any one organization.” Now they own they are under the control of a political organization.

Here is the paragraph Let's Encrypt added to their Subscription Agreement on 2026-06-04:

> You are not a person or entity that is:

> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;

> (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations;

> or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b).

> You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.

cassianoleal

13 hours ago

They could, but if the branch didn’t follow these laws, the main US branch would still be liable.

cromka

12 hours ago

It's about time SOME entities start moving from US entirely.

mikeyouse

4 hours ago

RISC-V Foundation did.. though they go out of their way to talk about it in terms that try not to piss anyone off..

> "Across 2018-2019, the RISC-V community has reflected on the geo-political landscape and we have heard concerns from around the world that investment in RISC-V must come with IP access continuity to ensure a long-term strategic investment. We first mentioned our intentions to move at the December 2018 summit. Incorporation in Switzerland has the effect of calming concerns of political disruption to the open collaboration model. RISC-V International does not maintain any commercial interest in products or services as a non-profit, membership organization. There have not been any export restrictions on RISC-V in the US and we have complied with all US laws. The move does not circumvent any existing restrictions, but rather alleviates uncertainty going forward.

> In March 2020, the RISC-V International Association was incorporated in Switzerland. Along with this, we shifted to a new, more inclusive membership structure. Members of RISC-V International have access to and participate in the development of the RISC-V ISA specification and extensions as well as related hardware and software. RISC-V has a Board of Directors composed of member representatives as well as a Technical Committee of work group leaders."

> RISC-V International has not incorporated in Switzerland based on any one country, company, government, or event. This move is reflective of community concern and managing strategic risk for our community investing in RISC-V for the next 50+ years.

> The IP contributed and produced by RISC-V International is held under industry and global standard licenses that are already open to leverage by any company regardless of jurisdiction. This licensing is a common open source approach to foster collaboration that is not tied to any geographic regulation. IP in the public domain has not been subject to export control.

https://riscv.org/about/

rafram

4 hours ago

Other countries sanction each other too.

cassianoleal

an hour ago

This is not about countries sanctioning each other. This is the US sanctioning a local company because a foreign company doesn’t follow certain US laws in foreign soil, where such laws don’t apply.

It’s a bit like the US arresting your mom at home in Texas because you ate a baggie of magic truffles in Amsterdam.

kube-system

20 minutes ago

The way you are using these words seems to indicate you might be confused about how this works.

The US has not "sanctioned" LetsEncrypt or ISRG. The US sanctions foreign entities as punishment for various reasons precisely because they are not subject to US law. That's the entire point of leveraging a sanction -- to pressure those outside of your legal jurisdiction. If they were in your jurisdiction, you'd simply arrest them.

People and organizations basically anywhere not permitted to do business with anyone your country has sanctioned. Anyone who does business internationally should be aware of their country's sanctioned list. That applies no matter where you live on the planet.

cassianoleal

a minute ago

This is not that though.

This is literally about a company that has a branch in the USA and another branch in another country, where it's bound by that country's laws. If the foreign entity which just so happens to be commercially linked to the one in the USA has any dealings with countries sanctioned by the US, the US branch is punished.

There was a case a few years ago where a public University in Brazil bought lab computers from Dell Brasil. Dell Brasil is a subsidiary of Dell, but it's 100% incorporated in Brazil, the computers were manufactured in Brazil, everything following Brazilian law. The computers were delivered with terms of service that prohibited them from being used for any dealings with US-sanctioned countries such as Iran and Cuba. The University was caught by surprise and questioned it, since they had many academic links with Cuban Universities, and Dell Brasil explained that.

I don't know how the whole ordeal ended. The Brazilian Federal Government got involved, I believe the Ministry of Exterior and the Ministry of Commerce and Industry both got involved and were at one point going to sue Dell Brasil. I suspect it ended with the University returning the computers and purchasing from another supplier.

The suggestion that Let's Encrypt could work around US sanctions by opening a branch in the EU falls under similar conditions, and the US branch would be liable if the EU subsidiary had dealings with US-sanctioned countries.

rafram

an hour ago

You're being very vague. Please explain what you mean? I don't see anything here about the US "sanctioning a local company," and I'm not aware of that being possible under US law.

cassianoleal

a few seconds ago

Please see my answer to the sibling comment.

cromka

33 minutes ago

"Clarifying Lawful Overseas Use of Data (CLOUD) Act."

PunchyHamster

an hour ago

completely independent entity would be far better option. Protocol is open after all, just need pointing to different vendor

Insimwytim

3 hours ago

Iran is blocking internet for months, US ...bans creation of secure connections - that'll show 'em!

Russian quasi-government structures are spending quadrillion of rubles on a TSPU (censorship system) to spy on Russian residents, US ...helps them by making snooping on what is currently encrypted traffic possible by banning accessible encryption!

jaas

2 hours ago

Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.

The terms of service update to clarify what we have always done, comply with relevant law, has not changed the situation for either country.

joshuaissac

an hour ago

> Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.

According to https://news.ycombinator.com/item?id=48457280 it affects all people ordinarily resident in those territories, not just their governments:

> You are not a person or entity that is:

> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;

> [other 'or' conditions]

jaas

14 minutes ago

Sanctions compliance is unfortunately fairly complex.

Let's Encrypt can issue certificates for non-government entities in Iran and Russia due to statutory exemptions protecting personal communications, alongside specific Office of Foreign Assets Control (OFAC) authorizations designed to promote Internet freedom and human rights.

We will look into whether we can make things more easily understandable in the subscriber agreement.

lioeters

an hour ago

I wonder what "ordinarily resident" means legally. Like has a permanent address there, even if they don't live there physically..?

Hundredth0006

17 minutes ago

Yes. If you are, for example, even a US citizen, permanently living in Crimea, you are still subject to limitations, imposed by sanctions.

john_strinlai

an hour ago

you should update the documents to reflect this stance.

"You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; "

this says nothing (edit: specific) about government (edit: only), and is applicable to normal people in those areas.

joemi

44 minutes ago

A government falls under "entity". So it's about normal people AND governments (and other entities).

Still needs updating if it's supposed to only apply to governments, though.

gnerd00

3 hours ago

wait until you find out about Facebook!

axiologist

10 hours ago

This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership. It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS. That's digital tyranny in disguise.

kube-system

7 minutes ago

The entire point of a trust model is to exclude people. That's the stated goal.

If you want encryption without trust, just use self-signed certs.

belorn

2 hours ago

While it seems like certificate authority has the primary control here, the real control lies in browsers and operative systems in which certificate authorities are trusted. Users also have, at least for the moment, control to add or remove certificate authorities, even if that control is slightly less clear for devices like smart phones.

Digital certificates that signs software packages are used to enforce exclusion by some manufacturers. Let's encrypt is not in that space to my knowledge, but it is a place where you the owner do not have the right to determine which certificate authority should be trusted, and generally the only one that is trusted is the manufacturer. Its arguable if we even should be calling such entities a certificate authority, even if they technically are the owner of the root certificate that signs the package.

MarleTangible

9 hours ago

I always saw it as a trust-chain and think that anyone is welcomed to create a root certificate and distribute it to whomever trusts them. Most simple services may not need TLS, but with the ISPs eavesdropping on our communication, a form of secure communication is required and the currently best solution we have requires a trust-chain to be built.

lesostep

37 minutes ago

The problem is that finding a root source of trust aren't easy this days. LE was neutral, now nobody is.

Russian government issued their new root certificate years ago.

Nobody trusted it enough to request a certificate from them or install it on their computers. Including almost all of the russian residents.

If Let's Encrypt enforces the rules, as written in pdf, a lot of people would lose a choice.

Frankly, even publishing a statement like that would make the scales of trust tip for some.

happosai

2 hours ago

It is such a great improvement that ISPs cannot eavesdrop us anymore... only for everyone to terminate TLS at cloudflare so they (and thus US government) can now eavesdrop everyone.

account42

5 hours ago

Do we also need to put all our letters into strongboxes before we send them?

Maybe we should have solve the ISP snooping problem by making that illegal instead.

theamk

4 hours ago

This just leaves every single public Wifi network - which used to mess with traffic a lot

cyanydeez

3 hours ago

Guys, we live in a society.

Parodper

6 hours ago

We could, and should, switch to DANE. Or else, switch to how X.509 was supposed to be used, with each country running a CA for their nationals.

theamk

5 hours ago

I trust governments much less that a conglomerate of competing corporations.

With all the problems with Web PKI, at least the bad actors are getting distrusted, and this provides a very strong enforcement on the rest. And Certificate Transparency makes sure the mis-issuance would be caught. It is not perfect by any means, but things are getting better.

With DANE (or other country-issued certificates), every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse. (In the past I'd say that only countries like Russia would do it.. but with today's climate, I am sure both US and many European countries will do that too)

gopher_space

11 minutes ago

> I trust governments much less that a conglomerate of competing corporations.

There’s no essential difference between the two from my perspective. Why are these my only choices?

Parodper

4 hours ago

> every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse.

Countries already have CA that issue certificates with more legal force than a handwritten signature. I can open a bank account, pay my taxes and sign up to all government services. But I can't use them for a webpage.

> With DANE (or other country-issued certificates)

DANE isn't a country-issued certificate. It's a scheme where you store your public keys on DNS records. Of course, now we have the issue that DNSSEC (signed DNS records) isn't widespread and the whole issue with DNS registries.

theamk

11 minutes ago

DANE is entirely dependent on DNSSEC, and DNSSEC is, by design, under the government control, with all the bureaucratic mess and mistakes this implies.

This would be pretty terrible if anyone actually cared about DNSSEC, but luckily for us, no one cares.. So let's keep things this way.

account42

5 hours ago

Pretty much any big government has a CA they can exert direct control over whenever needed.

theamk

4 hours ago

Maybe, but then can only do it once. Then they get caught, and their CA is distrusted. See Diginotar [0] for example.

And things only gotten better since - we now have CT logs, and browsers require them, so any mis-issuance can be detected automatically, by any interested third party.

If we go to DANE, we lose this all. "Oops, our CT uploader process failed, we will fix Real Soon(tm) we promise" - and what are browsers going to do? Distrust the entire country?

[0] https://blog.mozilla.org/security/2011/09/02/diginotar-remov...

Fnoord

28 minutes ago

The Dutch government didn't exercise control over Diginotar.

In the Dutch hacker scene, Diginotar was a meme. Everyone knew it was a mess there.

JumpCrisscross

3 hours ago

Side note: “DigiNotar BV was a Dutch certificate authority from 1998 to 2011. It was acquired in January 2011 by VASCO and subsequently declared bankrupt in September of the same year” [1].

I didn’t realize the slapped their face on the pavement right after being acquired.

[1] https://en.wikipedia.org/wiki/DigiNotar

thaumasiotes

3 hours ago

> I always saw it as a trust-chain and think that anyone is welcomed to create a root certificate and distribute it to whomever trusts them.

Note that phones already try to prevent you from using a certificate that you provide yourself.

palmotea

6 hours ago

> This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership. It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS. That's digital tyranny in disguise.

I think the "digital tyranny" is a side effect, not the main goal. They're "mainly a means" to prevent certain kinds of MITM attacks.

watwut

2 hours ago

I always thought the main goal was to force people to pay money for certificates.

ekr____

an hour ago

Let's Encrypt certificates are free.

account42

5 hours ago

You could that with a much saner approach like DANE.

franga2000

4 hours ago

Not back when SSL and the PKI ecosystem was developed.

Igrom

12 hours ago

It seems that, as soon as you transact with a sanctioned entity, you are globally in breach of the agreement and risking the revocation of all your certificates — also the ones for non-sanctioned countries.

Front matter:

   - it is called a "Subscriber Agreement" and not anything that suggests that its scope is a single certificate

   - it's a "contract [...] regarding Your [...] rights and duties relating to [...] Certificates" - plural
2.1 "Term":

  - "[the agreement] will remain in force during the entire period during which *any* of Your Certificates are valid" - plural
3.1 "Warranties":

  - "[by] requesting, accepting, or using *a* Let’s Encrypt Certificate" - plural

m2f2

15 hours ago

Is this a canary?

What's gonna happen if I were to begin or continue using one letsencrypt certificate from ... Greenland? Cuba? The EU?

Has letsencrypt been served with a subpoena?

tialaramex

an hour ago

> Has letsencrypt been served with a subpoena?

While it's certainly possible that ISRG has been served a subpoena because it appears the US DOJ is now a mix of hacks and incompetent buffoons, it wouldn't matter because the whole point is that they don't know anything - what you told them is literally logged publicly for everybody to see without even knowing how to spell "subpoena" let alone issue one.

Some people have this insane idea that somehow the CA has some secret which either they minted and sent to the CA, or the CA minted and gave them a copy and so the US government could get this secret with a subpoena - but the whole fucking point of a Public Key Infrastructure is that we're using Public Key Encryption, if we were OK with everybody having secrets all over the place this entire thing wouldn't be needed.

basilikum

37 minutes ago

They have the secret of the private keys used to sign certificates.

Looking at LavaBit^1 I really would not be so comfortable. The world and especially the US has not gotten more free since then.

[1]https://en.wikipedia.org/wiki/Lavabit

rafram

4 hours ago

Neither Greenland nor the EU has been sanctioned by the US.

nitwit005

4 hours ago

They haven't been sanctioned, yet, but we live in a time where that's a real possibility.

tempfile

3 hours ago

It is not exactly an outlandish suggestion that this may happen.

wnevets

3 hours ago

Maybe consolidating ~60% of the web's certificates on to a single provider was a mistake.

patmorgan23

3 hours ago

Well good thing everyone using the provider is using an open protocol and it's stupid easy to switch

wnevets

2 hours ago

Which free CA should I use instead of lets encrypt that has same browser support?

ygjb

2 hours ago

Actalis, based in Italy offers a free tier, with ACME https://www.actalis.com/subscription

ZeroSSL from Austria also has a limited free tier. https://zerossl.com/pricing/

I mean really, if you use lets encrypt for anything that runs in a production environment, the responsible thing to do is build a fallback to switch to another provider in case LE has a bad day (or hits a brick wall and needs to say, enforce export restrictions).

daneel_w

an hour ago

Worth noting that Actalis requires you to register an account with them in order to acquire the necessary authorization token for their ACME API. This poses a privacy/anonymity issue for some users. Last I checked, Actalis' free tier didn't support SAN either.

Add.: I created an account just now to see "what's what" and also found the notice, "Activate your free 90 days certificates. At the end of the free year, the services associated with the certificates will expire." which sort of sounds like it's just a 1-year free trial.

gruez

2 hours ago

ZeroSSL / BuyPass

ygjb

2 hours ago

Buypass no longer issues TLS certs since last year.

pratyahava

an hour ago

can you please suggest any alternatives to switch to? i hardly can find any alternative which provides free service and is a non-profit org at the same time.

joemi

38 minutes ago

Is Let's Encrypt the only provider of SSL certificates?

Genuine question! Because I assumed there were other places you could get a SSL certificate, but people in this thread seem to be implying that without Let's Encrypt, there's no way for people in those sanctioned territories to get a cert.

hinata08

29 minutes ago

If it was a genuine question, the genuine answer is it's the provider that democratised streamlined ACME certificate verification and made it for free

No account, no payment, a single bash command or a certbot that runs regularly and you have your own globally recognised certificate

Historically, providers used to make the most frictions so that they could justify absolutely crazy fees for signing any certificates. It doesn't goes down well in DevOps, it doesn't work with indies who don't have 3 to 4 digits figures to blow in httpS, everyone including organisations ended up making certificates authorities of their own to sign stuff... and let's encrypt was successful at making certificates easy, free and actually secure

herbst

31 minutes ago

If nothing has changed it's still the only one that's free and instant. Back in the day you'd had to pay $10/y and install manually

nicce

29 minutes ago

There are some options. actalis.com is European alternative but free tier is a bit less than Let's Encrypt.

Fnoord

30 minutes ago

> Is Let's Encrypt the only provider of SSL certificates?

No.

mrweasel

an hour ago

This should be one of those things that should be an quick EU win. Running Let's Encrypt is $3-4mill a year, the EU probably uses that on pencils.

The EU could easily bootstrap a Let's Encrypt competitor if it truly cared about removing dependencies on US based entities.

zajio1am

29 minutes ago

Yes, but EU would have to convince Google and Apple to get a new root certificate to browsers.

xxpor

36 minutes ago

Do you really think the EU wants to sign up for PR that’s essentially “the US is being too mean to Russia” right now?

flumpcakes

5 minutes ago

I think the EU should do it regardless of Russia. The EU should invest in its own technology and not depend so much on an increasingly undependable ally.

niemandhier

2 hours ago

It their right to do that.

But can we still trust them?

I am not well versed in how their systemwide certificate issuance works: If they have to add this to their terms to comply with their government, could the same government use pressure to leverage let’s encrypt to do harm.

karteum

9 hours ago

Can anyone explain me what went wrong with http://www.cacert.org/ and why they are not supported by any major browser ?

em-bee

7 hours ago

the wikipedia page has links to projects that removed CAcert where reasons are stated. the main one being that CAcert didn't complete a security audit or because they were not yet accepted by mozilla (because of the lack of an audit, but also because CAcert actually withdrew the request to be included). one group removed it because CAcert has a strict root redistribtion license that they can't follow.

LWN has a good writeup on the audit situation as of 2014: https://lwn.net/Articles/590879/

VortexLain

2 hours ago

Now this is very bad, as bad as it can get. As soon as all local services will stop working in sanctioned countries, those countries' governments will force all users to either install a root certificate or lose access to all local services and websites. And then it will be possible to use that root certificate for MITM attacks. In the worst case scenario, after the majority of users will install the root certificate, state DPIs will MITM all traffic and will block all un-MITMable traffic.

yurish

39 minutes ago

Don't understand why you have been downvoted. Russian government have already attempted to push forward their root certificate for banking using Yandex browser, now this.

piskov

a day ago

> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations; or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations

theamk

21 hours ago

Makes sense, they are US company. I am surprised it took them that long.

rwmj

13 hours ago

"US company must obey US law" doesn't make for a very interesting headline.

ceeam

10 hours ago

"The world should stop trusting the US companies" OTOH...

cyanydeez

3 hours ago

more optimistic would be "World should decentralize America's trust"

ohmg

10 hours ago

The headline is more « US law is batshit and extends well beyond its borders with real world consequences »

pavon

3 hours ago

This is not an example of that. It is perfectly within US jurisdiction to prevent US companies from doing business with sanctioned countries. That is the point of a sanction, and US is in good company in choosing to use sanctions as a diplomatic tool.

It is more of an example of how the internet/software industry is too consolidated to the US, and thus other countries are too dependent on the US in those areas. If the internet infrastructure was well distributed, then people in sanction countries could simply get certificates issued by a different CA, and in some cases they can. However, this is complicated by the fact that the list of trusted CAs is dominated by US organizations (Google, Mozilla, Apple, Microsoft). If you want to reach western audience you must use certs from a CA approved by them.

zajio1am

26 minutes ago

This is not specific to US law ...

ezbie

6 hours ago

Exactly. Ever since I was a kid I never understood how the US has jurisdiction way beyond their borders.

Then I graduated in International Relations and understood that the hole is much deeper than that.

Now it's pretty obvious with all the shit that trump has been doing, but back then me and much of the people I know were oblivious to what US power really means.

account42

5 hours ago

It is however a reminder that "just use LE" is not a valid response to concerns about protocols/APIs/browsers/etc requiring TLS.

floper_a

9 hours ago

That's just another reminder that no one from outside of US should deal with US companies.

bigfishrunning

2 hours ago

Of course not! just find viable alternatives to Microsoft, Apple, Mozilla, YCombinator, Google, Intel, AMD, ...

In all seriousness, as an American I'd love to see a healthier, more well-distributed tech industry, but I don't see many companies stepping up to provide competing services. It's my understanding that china has alternatives to many of these products/services, but I really don't see how anyone in Europe could possibly use a US-free internet.

Galanwe

an hour ago

> but I don't see many companies stepping up to provide competing services

Maybe because the US dropped most of its anti trust regulations, leading to ridiculously monopolistic practices such as "acquire everything that may be threatening".

bigfishrunning

an hour ago

When was the last time you heard about a European cellphone manufacturer, or social media network, or web browser being acquired by an American monopoly?

I can only think of Nokia, purchased by microsoft in 2014. Those phones ran windows CE before that even, so you could hardly have avoided the american tech industry.

All I'm trying to say is, it's impossible for Europeans to both A) be on the internet and B) avoid the US tech industry.

DoctorOetker

14 hours ago

> active eavesdropping (e.g., monster-in-the-middle attacks)

is this standard MitM, or is it some crucially distinct variation?

thephyber

14 hours ago

Man in the Middle Wiki:

> Also known as a monster-in-the-middle,[1][2] machine-in-the-middle,[3] meddler-in-the-middle,[4] manipulator-in-the-middle,[5][6] person-in-the-middle[7] (PITM), or adversary-in-the-middle[8] (AITM) attack.

walletdrainer

13 hours ago

Those sources feel more than slightly contrived.

nikolay

2 hours ago

Yeah, let everybody build and use their own services, and then the US will end up having less control and visibility. Great tactics!

42droids

16 hours ago

Has anyone got any experience with Zero SSL? https://zerossl.com/ It seems like a good EU alternative.

47282847

15 hours ago

EU? There’s almost zero information on the company, no privacy policy? The only place I found any mention is the footer, “HID Global Corporation, part of ASSA ABLOY”. Assa Abloy seems Swedish but HID Global is a US company as far as a quick search goes. But without a proper company info page and privacy policy I wouldn’t consider it anywhere near a “good alternative” regardless.

slau

15 hours ago

HID was originally American and Scottish, but became fully American in 1994.

HID was acquired by Assa Abloy in 2000. No idea whether that means we now consider it Swedish.

ZeroSSL used to be Austrian until their acquisition in 2024.

I used to work for a company that got acquired by HID. It looks like HID has retained their original offices in some form.

ZeroSSL

5 hours ago

Jumping in here since we’ve been seeing more mentions of ZeroSSL lately, likely related to the recent CA/B Forum discussions around 1‑year certificates and ACME automation.

- We’re based in Austria (ZeroSSL GmbH). The company was acquired by HID in 2024, which is part of Assa Abloy (Sweden).

- We’re not positioning ourselves as a purely EU-based CA substitute, and we generally don’t market it that way.

- For DV certs specifically, we act as a distributor. Under the hood these are Sectigo-issued certificates, similar to how other providers (for example Namecheap) operate.

Happy to clarify further if useful.

kruffalon

3 hours ago

> - We’re not positioning ourselves as a purely EU-based CA substitute, and we generally don’t market it that way.

OK, but in the context of this topic thr interesting part isn't your marketing but your jurisdiction.

Could you clarify which jurisdiction you operate under and a link on the ZeroSSL website that collaborates that?

Thank you <3

hoistbypetard

2 hours ago

Sectigo used to be Comodo's CA business. If memory serves, that business was purchased by a US PE firm and renamed "Sectigo". Sectigo Inc.'s corporate headquarters is now in Scottsdale, AZ.

There's no reason to believe they're any less subject to US jurisdiction than LetsEncrypt.

idoubtit

an hour ago

There were reason to believe they were less subject to US juridiction: their Subscriber Agreement is for "Sectigo Limited, a limited company formed under the laws of England and Wales". See https://www.sectigo.com/uploads/backgrounds/Certificate-Subs...

Sadly, their United Terms and Conditions in section 8.2 are even more restrictive than LE's. They reject any entity "located in, incorporated under the laws of, or owned (meaning 50% or greater ownership interest) or otherwise, directly or indirectly, controlled by, or acting on behalf of, a person located in, residing in, or organized under the laws of any country sanctioned under the laws of the U.S. or E.U." See https://www.sectigo.com/uploads/backgrounds/United-Terms-and...

From a layman point of view, it could even mean that the ICC and the UN are prohibited from using Sectigo. The Customer must have no "affiliates, officers, directors, or employees" that are on sanction lists, and the US have sanctioned some high-profile members of the UN and the ICC that spoke about the genocide in Gaza.

redrblackr

3 hours ago

Any plans on becoming an independent CA? Would certificates issued in your name also risk being affected by US sanctions trough sentigo?

orochimaaru

2 hours ago

If they do business in the US they will be expected to comply with US law - this includes their stock being traded on US stock exchanges.

If they don’t have any business in the US and any financial ties to the US they won’t be subject to the sanctions. But I believe it will create issues if they want to enter the US market.

nomadwastaken

13 hours ago

The privacy policy is under legal in the footer, exactly where I'd expect it to be honest. It also gives the company registration: > 1.1. We, ZeroSSL GmbH, FN 443956b (the “Company“) and below that the company address (registered in Austria).

Don't get me wrong, I agree that there is some lack of "who actually runs/controls this", especially on the about page where I expect such things to be.

At the very least it's not as transparent as I'd wish from a CA. E.g their Certificate Agreement is from Sectigo, so are they involved? No mention anywhere else from what I can see.

47282847

8 hours ago

I don’t see “legal” in the footer on mobile. Or any other link. Or a link to an About page in the main nav. There’s nothing.

matharmin

2 hours ago

I use them in some cases to avoid the rate limits on LetsEncrypt, and they have better support for some older platforms (like ancient Android versions), and I'm pretty happy so far. I have a paid account to support them, but it's not a requirement for ACME certs. It works without issue with Kubernetes Certbot, and seamless to switch between ZeroSSL and LetsEncrypt.

I can't comment on the EU part though - not that relevant in my case.

linsomniac

3 hours ago

There was some subtle issue with ZeroSSL's implementation of ACME that I ran into with, IIRC, lego and domain certs and there was a ~5 year old lego open issue about it. That was a couple years ago, might be fixed, but my understanding at the time was that it was an issue with Zero's ACME implementation, so there may be dragons.

slau

15 hours ago

3 90-day ACME certs for free. 180€/year for unlimited 90-day certs and 5 yearly ones.

That’s a pretty steep increase. I would almost be more interested in a monthly fee per cert.

nomadwastaken

12 hours ago

From their docs[0] this doesn't seem to apply if using ACME, but they don't exactly make that clear...

> By using ZeroSSL's ACME feature, you will be able to generate an unlimited amount of 90-day SSL certificates at no charge, also supporting multi-domain certificates and wildcards. Each certificate you create will be stored in your ZeroSSL account.

[0]: https://zerossl.com/documentation/acme/

matharmin

2 hours ago

Yeah, they don't make it that clear, but you get basically the same functionality as with LetsEncrypt for free, including wildcard certs. You basically only need to pay for manually issued certs, or some of their other additional features.

nickf

13 hours ago

ZeroSSL aren't an EU-based alternative, unfortunately.

patrakov

7 hours ago

It's Sectigo under the hood.

Panzerschrek

14 hours ago

Does it mean that russian/iranian web-sites using letsencrypt stop working and need to change their certificate provider?

altairprime

13 hours ago

Depends on whether LE is compelled to terminate service to BGP AS numbers hosted in U.S.-sanctioned countries, and whether LE continues operating out of the U.S..

account42

5 hours ago

Depending on how you are supposed to read "You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations." it could mean that you are not even allowed to use LE certificate to provide services to sanctioned entities as a random non-US company/person.

piskov

11 hours ago

They already revoced certificates for some russian sites

pratyahava

an hour ago

any details on that? links to people reporting it?

greatgib

3 hours ago

To be put in perspective with their push for very short live certificates, like 7 days, with the argument that anyone can easily get certificate from at any time.

But in fact, little by little you have all the stacks needed to be able to isolate some entities from internet at the us request in a very short time

OutOfHere

2 hours ago

I had the parent organization of LetsEncrypt (Internet Security Research Group) in my Will, but after reading this, I will remove it immediately. US sanctions harm too many innocents.

pxeger1

13 hours ago

How are they going to enforce this?

nickf

8 hours ago

I would imagine, as a CA that issues only DV certs, they'd disallow issuance to various ccTLDs, and perhaps stop newAccount registrations with email addresses at those ccTLDs. That's about as much as they could do - IP-blocking by region is ineffective and crude at best.

ComputerGuru

3 hours ago

This is bullshit on par with the Chinese firewall, meant to effectively prevent the (entire!) western world from information by parties deemed persona non-grata. SSL certificates are supposed to be about security, not geopolitics.

I'm pretty sure a LE server hitting an Iranian or North Korean endpoint and validating a crypto challenge does not break any OFAC or EAR rules, and no money changes hands. And if a non-US entity wants to do it, the US would just sanction them. Microsoft and Mozilla are certainly not going to include a North Korean or Russian state CA in the root trusted certs (and if they did, the US government could just threaten them with sanctions, too).

Hard not to say "we warned you" about making self-signed certs completely unusable in favor of a very centralized approach.

diimdeep

10 hours ago

the reach is by rough estimates ~2.5–6 million websites globally, 2–5 million of those in Russia and 0.3-1 million in Iran

Whatever USofA, it's not hard to have their own cosmodrome and certificates.

Tangential, in 2026 website certificates feel like nothing, disposable automation artifact, toxic max-security[1], vehicle for those who rent seek, fingerprint.

[1] https://tom7.org/httpv/httpv.pdf

phoe-krk

9 hours ago

And now imagine that one of the Trump tantrums contains an announcement of sanctions against the European Union.

ezbie

6 hours ago

What in the actual fuck?

jalospinoso

3 hours ago

The uninteresting version of this is “US entity follows US law.”

The interesting version is that Web PKI is not just cryptographic infrastructure. It is also a policy distribution system. A browser trust store, a CA, a subscriber agreement, revocation rules, export controls, and sanctions law all end up in the request path of "can this site speak HTTPS to normal users?"

That does not make Let’s Encrypt uniquely bad. Any CA has some jurisdiction, owners, contracts, root-program obligations, abuse process, and legal exposure. Moving the CA changes the governance surface; it does not remove governance.

But it does mean "just use Let’s Encrypt" is not a neutral answer when protocols, browsers, APIs, app stores, or regulators effectively require TLS. The operational dependency is not only ACME uptime and certificate issuance. It is also jurisdictional continuity.

The hard product question is what failure mode we want:

1. Web PKI: power concentrates in CAs, browsers, and root programs. 2. DANE/DNSSEC: power shifts toward DNS operators, registries, registrars, and governments. 3. Self-signed / TOFU / pinning: power shifts toward application-specific trust and worse UX. 4. Multiple CAs: better resilience, but still bounded by browser trust stores and legal chokepoints.

There is no apolitical trust system here. There are only different control planes with different failure modes.

The practical ask from Let’s Encrypt should be clarity: issuance vs renewal vs revocation, existing certs vs future certs, domain location vs subscriber location, hosting location vs user location, and how they interpret “use” of a certificate. Without that, operators are left guessing whether this is a narrow compliance clause or a broad infrastructure-risk event.

cynicalsecurity

3 hours ago

This actually makes sense. No freedom for the enemies of freedom.

hinata08

3 hours ago

the list of ppl under US sanctions is staggering

Europe starts to shield itself from the risk since Nicolas Guillou, the French ICC judge who issued a warrant against bibi got sanctioned (France officially protested about this case)

China is being successful at blocking US firms out of their supply chains (they already use Linux on Loongarch processors with some homemade architecture and pioneer RISC V), since a bunch of their companies also got sanctions for supplying the governement

US stands so much for freedom that it's the first country to refuse immigration to FIFA world cup teams and athletes, with Iranians not allowed to stay between games and Somali goalkeeper being turned away at the border. Germany itself didn't do for the 1936 Olympics.

So at best, they're only shooting themselves in the foot by showing any US component in a supply chain is a risk, while using US clouds were already a risk of loss of revenue from FISA requests to undercut your bid and rot your company and using US dollars for trade was already a liability

In the meantime, US companies can do anything, break any financial law and abuse every human right, they'll just sign DPAs to avoid prosecution

CrzyLngPwd

3 hours ago

But what if you're the baddies?

bigfishrunning

2 hours ago

Then try not to be completely dependent on the products of a company that is under the control of your enemy.

mswphd

3 hours ago

love thought-terminating cliches. really helps keep from actually thinking ever.

cynicalsecurity

3 hours ago

Your comment reads like a thought-terminating cliché. If Russia occupied your city, killed your family and friends and left you homeless, you might reconsider giving freedom to those who take it away from others. Unfortunately, sanctions are often very easy to evade.

contagiousflow

3 hours ago

Now imagine the USA did that to the city you live in...

hinata08

3 hours ago

it can't happen, they only attack civilians in countries that have weapons of mass destruction or have a evil economic system of socialized healthcare and labor market

They also don't like states that threaten business by turning workers into a commodity that you have to compensate each month ; Spain sunk the Maine ; and they had manifest destiny given from God to get rid of natives

Shish2k

3 hours ago

This is a reasonable point, if "enemies of freedom" and "enemies of America" are synonymous...

queenkjuul

2 hours ago

Ah right, that's why there's US sanctions on Israel?

Towaway69

14 hours ago

Sanctioned has a double meaning here[1]:

> 2. officially or formally ratified or confirmed.

> 3. penalized, especially by way of discipline or to force compliance with legal obligations.

So who can use lets encrypt? Those that are penalised or those that are confirmed.

[1] https://www.dictionary.com/browse/sanctioned

thephyber

14 hours ago

If you click the link…

> [You certify to LetsEncrypt that] …

> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations; or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.

gossamer

an hour ago

It took me a minute to understand the original post because the verb sanction means both itself and basically the opposite of itself. It would be better to say "any territory that the US has levied sanctions against". I thought LetsEncrypt had banned its usage in the US! The word for words like sanction is contronym.