Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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As someone who has been closely engaged with ICANN processes and the Universal Acceptance (UA) journey, I appreciate the effort invested by the UA Expert Working Group in compiling a structured set of stakeholder-oriented guidelines. However, it is important to recognize that the usefulness of this report is constrained by a foundational limitation: the Working Group operated within a narrowly predefined charter developed by ICANN org, without prior community consultation on whether those were the right questions to ask in the first place.
This distinction matters. The document focuses largely on how to encourage UA adoption through awareness, messaging, engagement, and capacity-building. While these are important, they reflect an assumption that the primary barrier to UA adoption is lack of understanding or technical readiness across stakeholders.
In practice, after nearly years of UA advocacy, the barriers are no longer primarily technical or educational they are structural. The charter framed the problem as: “How should ICANN promote UA?” Instead of: “Why has UA not achieved meaningful adoption despite years of promotion?”
Because the Working Group was not empowered to challenge this framing, the resulting recommendations understandably emphasize outreach mechanisms rather than ecosystem accountability. This leads to three systemic gaps in the report:
First, the recommendations rely heavily on voluntary adoption pathways. Experience shows that UA has stagnated precisely because it has remained a voluntary best practice rather than an operational expectation. Without procurement linkage, contractual obligations, or measurable compliance incentives, awareness alone will not move implementation.
Second, the measurement framework proposed focuses on activity indicators such as events, curriculum inclusion, or awareness initiatives. While useful for tracking engagement, these do not necessarily correlate with real-world UA readiness across software platforms, email systems, or DNS workflows. Measuring effort should not be mistaken for measuring progress.
Third, the process by which this work was conducted raises an important signal. UA is consistently described as critical to digital inclusion and the next round of gTLDs. Yet this strategic priority was addressed through a fully virtual working model with limited structured interaction across the broader ICANN community ecosystem. If UA is truly foundational to the future namespace, a deeper, more integrated engagement model would have been appropriate.
None of this diminishes the value of the guidelines themselves. They provide useful direction on stakeholder engagement across big tech, open-source ecosystems, governments, academia, and infrastructure providers. However, the community should view this document as a starting point not a solution framework.
The next phase of UA advancement must move beyond encouragement toward expectation.
UA readiness should gradually transition from being a recommended practice to becoming part of procurement norms, platform readiness benchmarks, and ecosystem accountability mechanisms. Without that shift, the risk remains that UA will continue to be widely discussed but unevenly implemented.
Community acknowledges the value of the UA EWG guidelines while noting that their impact is inherently constrained by the predefined and limited charter under which the Working Group operated. At this stage in the UA journey, the primary barriers are no longer technical they are structural and awareness-led approaches alone are unlikely to produce meaningful adoption.
ICANN Board should therefore view this expert group not as a time-bound advisory exercise, but as a strategic asset. Instead of limiting its role to addressing predefined charter questions, this group could evolve into a standing expert resource supporting the SOs, ACs, and UA-related initiatives through specialized sub-groups of ICANNS eco system.
Institutionalizing such expertise would allow ICANN to move from promotion to progress enabling this body to function as a long-term enabler and evaluator of UA readiness across the ecosystem. It could help assess the real impact of ICANN’s activities and provide periodic, experience-driven feedback to the ICANN Board on whether UA adoption is advancing in practice, not just in principle.
Community recognizes the value of the UA EWG guidelines while emphasizing that their impact is inherently limited by the narrowly predefined charter under which the Working Group operated. At this stage in the evolution of Universal Acceptance (UA), the primary barriers to adoption are no longer technical or awareness-related, but structural in nature. Continued reliance on outreach, messaging, and voluntary uptake is unlikely to drive meaningful implementation across the digital ecosystem.
The current moment calls for a shift in approach from promotion to accountability, and from awareness to measurable readiness. UA must gradually transition from being treated as a best-practice aspiration to becoming an operational expectation embedded within platforms, procurement frameworks, and ecosystem standards.
In this context, ICANN should consider leveraging the UA Expert Working Group as an ongoing strategic resource rather than a time-bound advisory mechanism. A standing expert body, working in coordination with SOs, ACs, and UA-related initiatives through specialized sub-groups, could provide continuity, institutional memory, and practical insight into real-world adoption challenges.
Such a structure would enable ICANN to better evaluate the effectiveness of its UA initiatives and measure actual ecosystem readiness over time. Periodic, experience-driven input from this expert group could assist the ICANN Board in understanding whether UA adoption is progressing in practice not just in principle and help align future efforts with tangible implementation outcomes.