The IPC strongly welcomes efforts to address the gaps identified in the analysis – including mandatory registrar participation, integration of privacy/proxy service data, clear timelines for urgent requests, accreditation of requestors, and system integration (API) – as well as additional gaps the IPC has observed during the RDRS pilot. We believe that closing these gaps is essential to the effectiveness of RDRS for requestors (including IP rights holders) and contracted parties alike.

The IPC strongly supports requiring all ICANN-accredited registrars and all registries to participate in the RDRS. IPC is concerned that the voluntary nature of the pilot depressed request volumes and skewed data, as fewer requestors used a system that didn’t cover many registrars. Requiring registries to participate in the RDRS will support compliance with registry specific legal obligations, such as those under the EU NIS2 Directive’s Article 28, ensure increased participation rates, and create standardization of disclosure processes that reduce friction and improve outcomes for requesters.

The IPC strongly supports requiring disclosure of underlying customer data for registrations using privacy or proxy services where the disclosure request is otherwise determined to warrant disclosure, and the use of a centralized request system (i.e. the RDRS or its successor) for this purpose.  At a minimum, the IPC strongly supports mandatory disclosure of underlying customer data in response to requests based on well-founded assertions of IP rights violations by the registrant that meet the criteria set forth in the PPSAI Final Report Annex B.