The draft Guidelines for Advancing Universal Acceptance Adoption provide a thoughtful and well-structured roadmap for ICANN’s engagement with diverse stakeholders. They clearly recognize UA as essential to enabling a multilingual Internet and supporting digital inclusion, as highlighted in the Executive Summary and Introduction (pages 3–4). The document also appropriately identifies ICANN’s role as a key coordinator of outreach, capacity development, and measurement.

However, the context in which these guidelines will be implemented has evolved. With the closure of the Universal Acceptance Steering Group after nearly a decade of service, ICANN no longer has a dedicated standing external body to guide long-term UA progress. This reality creates an opportunity to strengthen the draft by incorporating structural elements that support continuity, implementation ownership, and sustainability.

The guidelines currently position ICANN primarily as a coordinating entity. While coordination remains essential, long-term adoption requires an additional enabling role that supports distributed stewardship across the multistakeholder ecosystem. The document would benefit from explicitly recognizing this transition by introducing a continuity layer within ICANN’s community structure.

A practical way to achieve this is to enable nominated representatives from the Supporting Organizations and Advisory Committees to act as UA stewards within their respective stakeholder environments. These individuals are already positioned at the intersection of policy, operations, and industry engagement. Formalizing their role as UA liaisons would help sustain momentum in the absence of a centralized structure while embedding adoption responsibility across ICANN’s existing governance framework.

In addition, the guidelines outline numerous actions but do not yet clarify implementation ownership. Introducing a simple responsibility mapping that distinguishes between ICANN’s engagement role and community-led execution would help translate strategy into action without creating new institutional mechanisms.

The draft also defines UA broadly as encompassing both domain names and email addresses (page 3). In practice, however, the usability of multilingual identities depends heavily on Email Address Internationalization. The document would be strengthened by introducing a dedicated EAI adoption track that addresses enterprise communication systems, public service delivery, and authentication workflows. This would ensure that UA readiness reflects real-world functionality rather than theoretical compatibility.

Further, while the measurement framework includes awareness, policy, implementation, and capacity indicators (pages 22–23), reliance on self-reporting alone may not fully capture practical readiness. Complementing self-assessment with observable usability indicators—such as the ability of users to successfully interact across platforms using internationalized identities—would provide a more accurate view of adoption progress.

UA is referenced as a contributor to ICANN’s FY26–30 Strategic Plan (page 3), yet its long-term integration into broader planning cycles is not fully articulated. Embedding UA milestones within readiness considerations for initiatives such as the New gTLD Program would help ensure sustained relevance and visibility.

Finally, the document would benefit from incorporating a long-term sustainability perspective. UA adoption is not a short-term initiative but a gradual normalization process across infrastructure, applications, and user environments. Recognizing a phased evolution—from ICANN-led engagement to community stewardship and ultimately ecosystem-driven adoption—would align the framework with the realities of infrastructure transformation.

These refinements do not alter the intent of the guidelines; rather, they enhance their ability to operate in a post-UASG environment. By strengthening continuity, clarifying ownership, elevating EAI usability, and embedding distributed leadership, the framework can evolve from a coordination roadmap into a durable adoption model.

This submission acknowledges the value of the draft Guidelines for Advancing Universal Acceptance Adoption and supports their objective of promoting a multilingual and inclusive Internet.

In light of the closure of the Universal Acceptance Steering Group, the guidelines would benefit from incorporating mechanisms that ensure continuity and long-term stewardship. Enabling nominated representatives from Supporting Organizations and Advisory Committees to act as UA liaisons within their stakeholder ecosystems could help sustain momentum and embed adoption responsibility across ICANN’s multistakeholder structure.

The submission also recommends clarifying implementation ownership, strengthening emphasis on Email Address Internationalization as a practical usability layer, complementing self-reporting with observable readiness indicators, and integrating UA milestones into ICANN’s broader strategic initiatives.

With these modifications, the guidelines can support a transition from coordination toward sustained ecosystem adoption.