The draft presents a thoughtful and well-structured framework for advancing Universal Acceptance (UA). However, it remains overly reliant on advocacy, awareness-building, and voluntary adoption. Based on more than a decade of industry experience, the primary barriers to UA are no longer educational—they are structural, economic, and tied to implementation accountability. Continuing to emphasize awareness without creating enforceable demand signals risks limited progress. The document appropriately references public sector engagement and procurement levers (particularly in the context of policy support and government systems), but this needs to move from a supporting recommendation to a primary driver. ICANN, working closely with the GAC, should develop standardized UA procurement language that governments can adopt. This would ensure UA readiness becomes a baseline requirement for digital public services and infrastructure.

There is also a gap in governance and execution. A temporary working group model is not sufficient to drive measurable outcomes at a global scale. ICANN should transition this effort into a standing, CEO-led UA Expert Council with clearly defined KPIs, reporting mechanisms, and a multi-year roadmap. The measurement framework outlined in the document is directionally sound, but without ownership and accountability, it risks becoming a reporting exercise rather than a driver of change.

From a technology perspective, the guidelines do not adequately account for the shift toward AI-assisted software development. Modern development workflows increasingly rely on AI and LLM-based tools. Embedding UA validation, testing, and remediation into these environments would significantly accelerate adoption and reduce legacy technical debt. An “AI-first” approach should be considered as a core strategy, not an afterthought. Additionally, UA should be positioned as a foundational requirement for Digital Public Infrastructure. Governments moving toward digital-first or digital-only services must ensure UA compliance across systems before rollout, while maintaining appropriate non-digital alternatives during transition periods to avoid exclusion. Finally, the execution approach needs to better leverage the depth of expertise within the community. Broader participation from expert contributors should be encouraged to improve communication quality, stakeholder engagement, and regional relevance. Relying on a narrow set of voices limits effectiveness and does not reflect the strength of the broader UA ecosystem.

This submission supports the overall direction of the UA guidelines but recommends a shift from awareness-led efforts to accountability-driven implementation. Key recommendations include embedding UA requirements into government procurement frameworks, establishing a permanent and accountable governance structure, leveraging AI-driven development ecosystems to accelerate adoption, and positioning UA as a foundational requirement for inclusive digital public infrastructure. These steps will help ensure UA moves from concept to consistent, measurable implementation at scale.