[Gnso-epdp-team] FW: Response from ICANN Compliance re. registrations under the 2009 RAA

Alan Greenberg alan.greenberg at mcgill.ca
Tue Feb 5 00:19:54 UTC 2019

Kurt, that would be fine. But that is not "elimination of the field". The registrar "ensuring" must happen before the field disappears.

We have an escrow program to protect registrants against failures in registrars and registries. The escrow data going forward must always include contact info.

I am just about to name an alternate for tomorrow and will lose posting privileges to this list.


At 04/02/2019 07:07 PM, Kurt Pritz wrote:
Thanks for this Alan:

Might another approach be to write into the policy something to the effect that, “Recognizing that in the cases of some registrations there is an “Admin Contact” but no Registered Name Holder or any other contact, it is required that, in the eliminating the collection and maintenance of the administrative contact, the registrar will ensure that each registration will contain the name and contact information of some contact, e.g., the registered name holder.”

Something like that to let each registrar manage its own situation and also to give compliance a way to monitor registrations to ensure that there is contact information.

Best regards,


On Feb 4, 2019, at 3:58 PM, Alan Greenberg <alan.greenberg at mcgill.ca<mailto:alan.greenberg at mcgill.ca> > wrote:

Another alternative is to say that the Admin contacts are not to be collected for new, changed or transferred registrations (which are all subject to the 2013 RAA requirement for Registrant contact data) and that the fields will be eliminated once all registrars confirm that all of the registrations under their sponsorship have Registrant contact information.


At 04/02/2019 05:14 PM, Alan Greenberg wrote:
I do not believe that we can eliminate the Admin contact information (as currently recommended) without a concrete idea of how many registrations might be left without contact information and just a note that implementation should investigate the potential impact. If that investigation (if it is even possible given the data that ICANN possesses) we to show that there are a substantive number of such registrations, what could they do? We know that registrars have resisted the requirement to take corrective action on registration (which is why the validation/verification requirements in the 2013 RAA only apply when there are changes).

If we eliminate Admin fields, we must provide for ensuring that all registrations have contact information within a relatively short period of time.

The easy fix given the timeline is to not eliminate the Admin fields.


At 04/02/2019 08:19 AM, Marika Konings wrote:

Dear Alan G., all,

In relation to the question regarding the 2009 RAA you formulated a while back, note that ICANN Org had already provided a response:

Alan Greenberg̢۪s Question:

The EPDP is requesting that ICANN Org confirm that all registrars are now operating under the 2013 RAA.

The EPDP is requesting that ICANN Org provide its interpretation of the requirement under the RAA Data retention Specification 1.1 whether registrars, as part of their adoption of the 2013 RAA, are required to ensure that Registrant contact email and telephone fields are completed, or whether the phrase "shall maintain that information" (which was validly allowed to be blank at registration time) allows them to preserve any empty Registrant contact fields. If the former, is Contractual Compliance taking any action to ensure that registrars fulfill this obligation?

ICANN org Compliance Response:

Registrars are not required to collect additional contact information for 2009 Registrar Accreditation Agreement (RAA) registrations. However, registrars may be required to update existing contact information for 2009 RAA registrations when there is a triggering event under the 2013 RAA that may require them to do so (e.g., the domain name is an inbound transfer, the registrant changes, there is information to suggest the current contact information is incorrect).

This response is also posted here: https://community.icann.org/x/ahppBQ.

Please let us know if this does not sufficiently address your question. In order to ensure this issue is not overlooked during the implementation phase, would it be helpful to add a sentence along the following lines in the implementation part of the report: “As part of the implementation, consideration needs toto be given to the potential impact of these policy recommendations on legacy registrations that without additional mitigation could end up with no contact information if the administrative contact is the only information currently available (this could be the case for a limited number of registrations that are still under the 2009 Registrar Accreditation Agreement)”?

Best regards,

Caitlin, Berry and Marika

Marika Konings
Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Namees and Numbers (ICANN)
Email: marika.konings at icann.org<mailto:marika.konings at icann.org>

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