Introduction

The ccNSO Universal Acceptance Committee (UAC) is pleased to offer its response to the call for public comments on the draft Guidelines for Advancing UA Adoption. For avoidance of misunderstanding, the UAC was mandated by the ccNSO Council to submit a comment on its own behalf. The views expressed in this comment should not be interpreted as views from any of the ccTLDs Managers participating in the UAC nor from the ccNSO membership or Council. 

ICANN has asked the community to review the guideline and provide input on:

- Any gaps in the proposed guidelines 

- Any challenges in implementing the recommendations. 

- How these guidelines should be prioritized for implementation.

In the balance of this comment, the UAC will first make some general observations and then address the three (3) questions.

General observations

The UAC expresses its appreciation and support the development of guidance to improve UA readiness. The ccNSO UAC recognizes the importance of Universal Acceptance (UA) in enabling a more inclusive and multilingual Internet, particularly in the context of country code top-level domain (ccTLD) operations and the increasing deployment of Internationalized Domain Names (IDNs). 

Specific input UAC on the 3 questions 

Q1. Gaps in the proposed guidelines

The UAC notes that the primary focus of the guideline is on external stakeholders, with limited reference to the roles of ICANN community structures, including Supporting Organizations and Advisory Committees, in facilitating UA adoption. The UAC suggests that greater clarity on how these bodies could contribute to awareness-raising, coordination, and capacity development would strengthen the overall framework.

The guideline does not clearly define an implementation framework, including measurable indicators, monitoring and evaluation mechanisms, or accountability and learning structures. In the view of the UAC, such a structured approach to monitoring and evaluation to track progress should be jointly developed by ICANN and the relevant stakeholders to assess the impact and effectiveness of implementation of UA across different stakeholder groups, including ccTLD operators, and by ICANN.

The UAC believes it is valuable to highlight that relevant parts of the ICANN community, including ICANN itself, use UA monitoring and (self)evaluation tools.  Additionally, UAC believes it is important to include reporting on the current situation and planned measures to  improve UA. 

The UAC suggests to include a reference to existing tools used by  regional ccTLD organisations (such as APTLD, CENTR) and ccTLDs  who are actively involved in the sphere of IDNs and UA and explore possible synergies to achieve the objectives (e.g. the research project idnworldreport.eu) in the context of point 24. “Consider Developing an Issues Report for UA Adoption”.

Further, the UAC suggests that it may be necessary to identify additional external stakeholders who could be involved in UA implementation. The UAC notes that regional and national IGF forums, IG summer schools and Youth tracks on Internet Governance are now playing one of the practical mechanisms for UA awareness raising and training in UA adoption skills. 

Further, the UAC notes that the guideline does not address the role of emerging technologies that could support and accelerate Universal Acceptance (UA) adoption, such as artificial intelligence (AI). AI-based tools and techniques could potentially enhance UA readiness through automated detection of non-compliant applications, large-scale testing, code remediation support, and improved validation of domain name and email handling across software systems. In the context of this point we also refer to the presentations and discussion of the joint ccNSO UAC - Tech WG Day session during ICANN85, where the topic of AI and UA was explored.

The UAC also suggests that It is worth taking into account and including into the guideline points regarding further monitoring and analysis of any security and operational risks that could be could caused by IDN and email address internationalization, e.g. homoglyph attacks, gaps in UA compatibility of different systems,  IDN Variants, etc. 

The UAC also observes that the guideline does not explicitly address its own lifecycle, including whether a formal process exists for periodic evaluation and updates to reflect evolving UA requirements and operational experiences.

The UAC believes that also addressing these forward-looking considerations would strengthen the technical relevance of the guideline and better reflect opportunities for scalable and automated approaches to advance UA adoption.

Q2. Challenges in implementing the recommendations

The UAC notes that from an operational perspective, ccTLD operators may face challenges in translating high-level recommendations into practical implementation steps. In particular, the lack of detailed guidance on engaging with technical stakeholders—such as open-source communities, software vendors, and application developers—may limit the effectiveness of efforts to achieve UA readiness at the software and application layers. It would be beneficial if, as part of implementation of the guideline, concrete steps and/or use cases are developed to assist ccTLD operators and others.  

Furthermore, influencing software development lifecycles and ensuring compatibility with UA requirements across diverse systems and platforms remains a complex undertaking. This is especially relevant for IDN deployment and email address internationalization, where dependencies on third-party software and global standards can introduce additional constraints.

Q3. Prioritization of implementation

To support effective adoption, the UAC agrees that the guidelines could benefit from clearer prioritization of implementation of actions. The UAC suggests that  particularly those activities with the highest impact on UA readiness within the DNS ecosystem and registry operations are prioritized.

Priority could be given to areas such as improving software compatibility, addressing validation limitations, and supporting IDN and email address internationalization at the application level. In parallel, the development of a concise, policy-oriented version of the guidelines may facilitate engagement with decision-makers and support broader dissemination.

Establishing phased or prioritized implementation pathways, supported by measurable milestones and reporting mechanisms, would assist ccTLD operators and other stakeholders in aligning efforts and allocating resources effectively. Formulating metrics on  UA progress of stakeholders and publishing the results - as suggested above under “Gaps in the proposed Guideline” -  would encourage stakeholders to include UA progress as part of their corporate strategies alongside with the social responsibilities roles.

The UAC appreciates the opportunity to provide input on the Draft Guidelines for Advancing UA Adoption and looks forward to continued engagement on this topic.

On behalf of the ccNSO Universal Acceptance Committee (UAC)

Abdalmonem Galila, UAC chair

Regina Fuchsová, UAC vice chair

The UAC expresses its appreciation and support the development of guidance to improve UA readiness. The ccNSO UAC recognizes the importance of Universal Acceptance (UA) in enabling a more inclusive and multilingual Internet, particularly in the context of country code top-level domain (ccTLD) operations and the increasing deployment of Internationalized Domain Names (IDNs). 

Overall, the UAC considers the guidelines a useful foundation but notes several areas where further development would strengthen their effectiveness and practical applicability. In particular, the UAC highlights the need for clearer articulation of the roles of ICANN community structures, as well as a more robust implementation framework, including prioritization of actions, measurable indicators, and monitoring and evaluation mechanisms. The UAC also emphasizes the importance of leveraging existing tools and initiatives within the ccTLD community, expanding stakeholder engagement, and considering emerging technologies such as AI to support scalable UA adoption.

From an operational perspective, the UAC notes that translating high-level recommendations into practical steps may be challenging, particularly in engaging technical stakeholders and addressing software and application-layer dependencies. To address this, the UAC encourages the development of concrete use cases, phased implementation pathways, and improved guidance on priority areas such as software compatibility, IDNs, and email address internationalization. The UAC further underscores the importance of addressing potential security and operational risks, as well as establishing a lifecycle for regular review and updates of the guidelines.

Overall, the UAC supports a more structured, measurable, and forward-looking approach to UA adoption, and looks forward to continued collaboration to enhance the guide