Public Comment

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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Submissions for this Proceeding

Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation

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Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Wenban-Smith, Nick
15 October 2025

Submission Summary:

According to official statistics from the UK government (Cybersecurity Breaches Survey 2024) half of UK businesses report having experienced some form of cyber security breach or attack in the previous 12 months. Phishing is cited as being by far the most common attack vector, followed by impersonation in emails or online, and viruses and other malware. Phishing is also commonly cited as the most common form of DNS Abuse, and increasing rapidl...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Non-Commercial Stakeholder Group - NCSG
15 October 2025

Submission Summary:

The issue of DNS abuse mitigation is not a new one; however, with the contractual amendments to Registrar Accreditation Agreements (RAAs) to mitigate DNS abuse having come into force, registries and registrars must now "promptly take the appropriate mitigation action(s) reasonably necessary" to disrupt the abuse. Yet the quest...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - CleanDNS
08 October 2025

Submission Summary:

CleanDNS welcomes ICANN’s initiative to address DNS abuse through targeted policy development. We strongly support the prioritisation of two key issues: Associated Domain Checks and Unrestricted API Access for High-Volume Registrations.

Associated Domain Checks: Malicious actors rarely use a single domain. CleanDNS advocates for registrars to investigate domains linked to abusive account...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Fraudkillers.org
08 October 2025

Submission Summary:

The submission advocates for the expansion of DNS Abuse definitions to include "Scams and Fraud". It highlights the need to recognize various fraudulent activities that impact users and the security of the DNS.


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Messaging, Malware and Mobile Anti-Abuse Working Group ( M3AAWG )
07 October 2025

Submission Summary:

The GNSO is considering policy-making ideas to curb the abuse of domain names. In our full comment document, M3AAWG evaluates these ideas in detail for effectiveness, practicality, and impact. M3AAWG is a global, technology-neutral industry association that develops cooperative approaches for fighting online abuse. M3AAWG’s members are experts at fighting DNS abuses including malware, spam, phishing, botnets, DoS attacks, and other online expl...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Omar, Isaac
07 October 2025

Submission Summary:

This comment identifies a key gap: the absence of a standardized, audit‑ready way to handle subdomain abuse. Attackers exploit disposable subdomains (e.g., login.bank123.com) for phishing and malware, which appear and vanish without lifecycle logging. This leaves contracted parties unable to demonstrate compliance with RA §4.2 and RAA §3.18 obligations to act promptly on abuse.

The proposed safeguard approaches — the URL Resolution Surfa...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - MAROOFI, Sourena
16 September 2025

Submission Summary:

Important Considerations Based on My Personal Experience with DNS Abuse Mitigation and Reporting.