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.

closed Initial Report on the Transfer Policy Review - Phase 1(a)

RequestersGeneric Names Supporting Organization (GNSO)


This Public Comment proceeding was initially scheduled to remain open from 21 June 2022 through 2 August 2022. The Public Comment proceeding was extended by two weeks in response to requests for additional time to submit input. The working group received a total of 34 submissions from groups, organizations, and individuals. 

The working group is now beginning a thorough review of the Public Comment submissions received on this Initial Report and will consider whether any changes need to be made to its Phase 1(a) recommendations. 

What We Received Input On

The working group is seeking input on the preliminary recommendations contained in this Initial Report as well as several outstanding questions on which the working group has not yet reached agreement. The Public Comment proceeding is presented as a series of structured questions. To preview all questions, please refer to a Word version of the form here.

It is important that any comments you provide include rationale. The Working Group is interested in your reasoning so that the conclusions reached and the issues discussed by the working can be tested against the reasoning of others.

Proposals For Your Input
Transfer Policy Review Initial Report (pdf, 966.43 KB)


The Transfer Policy, formerly referred to as the Inter‐Registrar Transfer Policy (IRTP), is an ICANN consensus policy that went into effect on 12 November 2004. The policy governs the procedure and requirements for registrants to transfer their domain names from one Registrar to another, also referred to as an inter-Registrar transfer. The goal of the Transfer Policy was to provide for enhanced domain name portability, resulting in greater consumer and business choice and enabling registrants to select the Registrar that offers the best services and price for their needs.

In February 2021, the GNSO Council initiated a two-phased policy development process (PDP) to review the Transfer Policy. The PDP is tasked with addressing the following topics:

  • Phase 1(a): Form of Authorization (FOA) (including EPDP Phase 1, Recommendation 27, Wave 1 FOA issues), AuthInfo Codes, and Denying (NACKing) transfers.
  • Phase 1(b): Change of Registrant (including EPDP Phase 1, Recommendation 27, Wave 1 Change of Registrant issues).
  • Phase 2: Transfer Emergency Action Contact and reversing inter-Registrar transfers, Transfer Dispute Resolution Policy (including EPDP Phase 1, Recommendation 27, Wave 1 TDRP issues), ICANN-approved transfers.

For additional background on this PDP, please refer to Annex A of the Phase 1(a) Initial Report.