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Submissions for this Proceeding
Second Draft of the RIR Governance Document
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Submission Summary:
Thank you for the opportunity to provide feedback on the “Governance Document for the Recognition, Maintenance, and Derecognition of RIRs (Version 2 (DRAFT)). Having spoken with many members of the global Internet community, this e-mail attempts to capture the collective feedback discussed. We extend our sincere appreciation to the NRO Number Council (NRO NC) and all community members who have dedicated significant time and effort to producing...
Submission Summary:
The ICANN Business Constituency (BC) supports stronger governance, security, and accountability frameworks for Regional Internet Registries (RIRs). The BC urges clearer safeguards against governance capture, defined derecognition criteria, and measurable oversight mechanisms. It also calls for RIRs to adopt auditable cybersecurity standards such as NIST or ISO 27001 to enhance transparency, trust, and operational integrity essential for busine...
Submission Summary:
Amazon supports the second revised draft of the Internet Coordination Policy - 2 (ICP-2), also referred to as the Governance Document for the Recognition, Operation, and Derecognition of RIRs. We would like to thank the volunteers for their important work. This draft provides crucial additional stability to the RIR system by providing for much needed emergency continuity procedures, improved mechanisms for auditing, recognition and derecogniti...
Submission Summary:
The Registries Stakeholder Group (RySG) endorses the second revised draft of the Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries and RySG recognizes that stable and predictable Regional Internet Registry (RIR) operations are crucial for our members and all gTLD registries.
The RySG made suggestions for refinement of Article 5 for the RIRs to consider during implementation.
Submission Summary:
Netnod welcomes the opportunity to provide feedback on the draft Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries (RIR Governance Document) Version 2.
Netnod is firmly committed to the multi-stakeholder governance staked out in the draft document. The RIR system should to a large extent be self-governed with accountability structures within the larger Internet coord...
Submission Summary:
The Government of India welcomes Version 2 of the RIR Governance Document as an important step toward transparency and accountability in the recognition, operation, and derecognition of Regional Internet Registries (RIRs). However, several key governance safeguards and clarifications remain essential for fairness, neutrality, and equitable participation across all regions.
India strongly recommends establishment of an Independ...
Submission Summary:
While APRALO welcomes the improvements made in the second draft of the RIR Governance Document, there are a few areas in this Version 2 document that need improvement. Please find attached our detailed submission.
Submission Summary:
The European Commission, Germany, the Netherlands, Denmark, Portugal, Spain and Italy welcome the publication of the Second Draft of the RIR Governance Document and commend the Address Supporting Organization (ASO), the drafting team, and ICANN staff for the transparent and inclusive process that has led to clear improvements over the first version.
The new draft strengthens the governance of RIRs by clarifying recognition and dere...
Submission Summary:
The Registrar Stakeholder Group (RrSG) appreciates the opportunity to comment. The Regional Internet Registry (RIR) system is fundamental to the function of domain names. The RrSG welcomes the ASO’s work to ensure that there is more clarity, transparency, accountability, and procedural flow with regard to Operation, Recognition, and Derecognition of RIRs.
Submission Summary:
Please receive feedback comments on the RIR Governance Document Version 2 from the Caribbean Telecommunications Union (CTU). Two attachments are being submitted: one is a narrative document summarising the comments and the other is a slightly "marked up" version of the Governance Document with the comments in context.
Submission Summary:
Tucows welcomes the opportunity to comment on the second draft of the Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries (“RIR Governance Model”). The Regional Internet Registry (RIR) system is fundamental to the Internet and the DNS and while these recommended rules and criteria, in conjunction with the creation of guiding principles to outline the expectations of RIRs in the ecosystem, will ...
Submission Summary:
Smart Africa welcomes the opportunity to contribute to the ICP-2 review and strongly supports the effort to update this critical governance framework.
Smart Africa’s position emphasizes:
Clearer procedures for recognition and re-recognition of RIRs;
Institutional safeguards against capture and legal paralysis;
Mandatory operational continuity measures such as data escrow;
Adoption of&nbs...
Submission Summary:
The Root Server System Advisory Committee (RSSAC) would like to thank the Address Supporting Organization (ASO) for their continued work on version 2 of the draft Governance Document for the Recognition, Maintenance, and Derecognition of Regional Internet Registries (RIRs). The RSSAC supports the ASO’s work in updating ICP-2 and the process being followed. This effort is both timely and necessary, and the RSSAC appreciates all the hard work be...
Submission Summary:
Subject: Amendment to the Proposed Draft of Paragraph 2.6 of the Governance Document for the Recognition, Maintenance, and Derecognition of Regional Internet Registries (“Governance Document”)
It is proposed for the phrase “at its complete discretion” in paragraph 2.6 of the Governance Document to be reconsidered, by rephrasing or omitting the said phrase to better reflect a more collaborative...
Submission Summary:
Please find attached (PDF) the ALAC Statement on the Second Draft of the RIR Governance Document.
Ratification information is included on the cover page.
Kind regards,
ICANN Policy Staff in support of the At-Large Community
Website: atlarge.icann.org
Facebook:facebook.com/icannatlarge
Submission Summary:
The ISPCP welcomes this new opportunity to comment on the revised RIR Governance Document.
Our previous comments can be found on the ISPCP webpage:
- https://ispcp.memberclicks.net/assets/docs/PolicyStatements/2025...
Submission Summary:
1.Emergency continuity plans are well-intentioned, though the fixed 90-day limit may be too rigid for complex crises.
2.Criteria for recognizing new RIRs are solid, but regional realignment could risk instability without stronger safeguards.
3.Control safeguards are important, but the monitoring of affiliated entities needs more clarity.
4.ICANN’s limited authority is a good check, though contingency plans for deadlock scenar...
Submission Summary:
The revised RIR Governance Document (v2, 28 August 2025) strengthens clarity of responsibilities from recognition to derecognition. However, three critical gaps remain:
1. Audit (Article 4.2) - Audit is defined as a formal obligation, but without measurable metrics, logs, or drift indicators. No escalation mechanism is foreseen for audit deviations, and no definition of practical conformity (TrueClaim) is provided. This risks ...