While I support the Draft Guidelines for Advancing UA Adoption, I am writing to highlight several critical policy and technical gaps that must be addressed to ensure the Internet is truly inclusive and stable for all users regardless of script or language.

1. Critical Gap in Accessibility Tools The guidelines explicitly acknowledge that support for Internationalized Domain Names (IDNs) in accessibility tools, such as screen readers, was "not explicitly taken into consideration" and requires further work. From a policy standpoint, any framework promoting "digital inclusion" and "human rights" is incomplete if it fails to mandate standards for assistive technologies. ICANN must prioritize technical studies to integrate UA requirements into the tools used by people with disabilities.

2. Policy Void for Registry and Registrar Accountability The draft suggests "exploring" policies and developing an "issues report" to address UA support within the DNS industry. This indicates a current lack of a mandatory policy framework for registries and registrars. Given that UA issues can "dilute consumer trust in the DNS," ICANN should move beyond exploration and define clear, enforceable UA compliance requirements within industry agreements to ensure that customers can use internationalized email addresses throughout the registration process.

3. Procurement and Regulatory Gaps While the guidelines recommend that governments include UA as a "must-have" in procurement requirements, this remains a recommendation rather than a global policy standard. There is a significant gap in transitioning these suggestions into national legislative frameworks. ICANN should work more closely with the GAC to provide model "UA Procurement Language" that governments can directly adopt into law to create market demand.

4. Data and Measurement Gaps The document notes that data collection is the "most elaborate and expensive step," yet there is no standardized, automated framework for stakeholders to self-report their progress. Relying on voluntary reporting creates a policy gap in oversight and accountability. ICANN should lead the development of a consolidated UA reporting dashboard with standardized templates to ensure reliable, comparable data.

Conclusion To achieve the goals of the FY26–30 Strategic Plan, these guidelines must evolve from "strategic engagement" to enforceable policy directives, particularly concerning accessibility, industry accountability, and mandatory procurement standards.

This submission identifies four primary policy gaps in the draft guidelines: the exclusion of accessibility tools (e.g., screen readers), the lack of mandatory requirements for registries and registrars, the absence of standardized public procurement laws, and the lack of a formal self-reporting framework for UA-readiness. As a commenter I urge ICANN to move from voluntary recommendations to enforceable policy mandates to ensure a multilingual and inclusive Internet.