ICANN and the UA Expert Working Group deserve recognition for producing a comprehensive and timely framework that clearly positions Universal Acceptance as a foundational enabler of digital inclusion and a necessary element for the success of the New gTLD Program and the multilingual evolution of the Internet. The document reflects thoughtful multi-stakeholder input and establishes a useful strategic direction.

However, for UA to move beyond awareness and into meaningful implementation, several structural and operational gaps should be addressed.

The draft correctly identifies ICANN org as a coordinating body, but it does not sufficiently define implementation ownership. Without clarity on who leads execution, who supports adoption, and how accountability is measured, UA risks remaining an advocacy initiative rather than becoming an operational reality. Introducing a defined implementation leadership structure, supported by stakeholder responsibility mapping and time-bound adoption pathways, would strengthen the transition from strategy to execution.

The framework also acknowledges the well-known “chicken-and-egg” dependency between infrastructure and applications, yet stops short of addressing how market demand will be created. Awareness alone will not unlock adoption. UA readiness must be accompanied by demand signals that incentivize adoption across platforms and service providers. Procurement-linked requirements, certification frameworks, and alignment with public sector digital policies could play a meaningful role in generating that demand.

Another area that would benefit from stronger emphasis is Email Address Internationalization. While referenced, the draft largely treats UA as a domain compatibility issue. In practice, email identity represents the primary usability layer of the Internet. Without operational EAI readiness across enterprise systems, government platforms, and service delivery environments, UA adoption will remain incomplete. A dedicated implementation pathway for EAI would strengthen the framework significantly.

The current approach relies heavily on voluntary adoption and self-reporting. While appropriate in early awareness phases, infrastructure transformation typically requires stronger ecosystem signals. Procurement alignment, readiness benchmarks, and policy enablement mechanisms could help move adoption from optional to expected without undermining the multi-stakeholder model.

The document also recognizes the importance of end-to-end user journeys but does not operationalize how usability will be validated. Introducing a UA user journey testing framework, including real-world cross-platform validation, would provide practical insight into readiness beyond theoretical compliance.

Beyond structural improvements, continuity of expertise is critical. UA adoption is inherently long-term and technically layered. The Expert Working Group represents a rare concentration of institutional knowledge and global perspective. Maintaining structured engagement of this group, or a defined subset, would help support implementation, guide ecosystem alignment, and sustain momentum. Their continued involvement could also assist governments, industry, and technical communities navigating adoption pathways.

Alignment with ICANN’s FY26–30 Strategic Plan should be strengthened through a mechanism that connects expert guidance with implementation progress. The group’s insights could contribute meaningfully to readiness considerations for the New gTLD round and broader digital inclusion objectives.

At the community level, UA adoption will benefit from distributed ownership. Nominated representatives from ALAC, GNSO, GAC, ccNSO, and SSAC could serve as UA liaisons within their respective ecosystems. Acting as bridges between ICANN strategy and stakeholder communities, these liaisons could support implementation efforts and represent UA priorities externally.

Recognition of the Expert Working Group’s contribution would also reinforce ICANN’s commitment to multilingual inclusion. Facilitating structured interaction between these experts and the broader community at future ICANN meetings would help sustain engagement and encourage adoption.

The draft provides a strong strategic base. The next phase should focus on strengthening implementation ownership, enabling demand creation, emphasizing EAI readiness, introducing usability validation mechanisms, and ensuring continuity of expert guidance.

With these additions, UA can transition from a strategic aspiration to an operational reality that supports inclusive digital participation worldwide.

I do acknowledge the comprehensive work of the UA Expert Working Group in establishing a strong strategic framework for advancing Universal Acceptance and supporting ICANN’s broader digital inclusion objectives.

While the draft provides a valuable foundation, several structural enhancements would help move UA from awareness toward real-world implementation. These include clearer implementation ownership, stronger mechanisms for creating market demand, greater emphasis on Email Address Internationalization, and practical validation of end-user usability across platforms.

The submission also highlights the importance of maintaining continuity of expertise by retaining structured engagement with the Expert Working Group to support implementation, guide ecosystem alignment, and assist in readiness for the New gTLD Program.

Additionally, strengthening alignment with ICANN’s FY26–30 Strategic Plan and enabling distributed leadership through community-level UA liaisons could help embed adoption across the multi-stakeholder ecosystem.

With these refinements, the guidelines can evolve from a strategic roadmap into an actionable framework that supports meaningful UA adoption and advances multilingual digital participation globally.