I commend the UA Expert Working Group for developing a structured and stakeholder-sensitive approach to advancing Universal Acceptance. The report appropriately recognizes UA as both a technical standardization issue and a governance coordination challenge, particularly in the context of the New gTLD Program: 2026 Round and broader digital inclusion goals.

1. Gaps in the Proposed Guidelines

While the guidelines comprehensively map stakeholder roles, they would benefit from stronger articulation of incentive structures and accountability mechanisms. Adoption across key actors particularly large platforms, software vendors, and hosting providers remains uneven due to limited enforcement or economic motivation. Embedding compliance signaling (e.g., UA readiness benchmarks, certification models, or procurement-linked requirements) could strengthen uptake.

Additionally, there is scope to better integrate UA within adjacent governance domains, such as digital public infrastructure (DPI), digital identity systems, and multilingual Internet access frameworks. UA should be positioned as a foundational interoperability layer, not an isolated technical objective.

2. Implementation Challenges

A key challenge lies in the fragmentation of implementation responsibility across heterogeneous actors (open-source communities, enterprise vendors, and public sector systems). Legacy system dependencies, lack of standardized testing environments, and insufficient developer awareness continue to hinder adoption.

To address this, ICANN could prioritize:

Development of reference implementations and interoperable testbeds

Expansion of developer-centric tooling and automated validation frameworks

Targeted engagement with system administrators and DevOps communities, where implementation bottlenecks often persist

3. Measurement Framework (Effort and Outcomes)

The proposed framework for measuring awareness, policy support, implementation, and capacity development is a strong foundation. However, it should move beyond activity-based metrics toward outcome-oriented indicators, such as:

Percentage of top global and regional platforms supporting EAI (Email Address Internationalization)

UA compliance across public sector digital services

Reduction in failure rates for IDN/email validation across commonly used applications

Standardized, publicly accessible UA readiness indices could improve transparency and benchmarking across regions and sectors.

4. Prioritization of Guidelines

For effective implementation, prioritization should follow a layered approach:

Core Infrastructure Readiness – DNS, email systems, and major platforms

Developer Ecosystem Enablement – tools, libraries, and training

Policy and Procurement Integration – especially in government and intergovernmental systems

Awareness and Capacity Building – academia and emerging stakeholder groups

Focusing first on high-impact infrastructure and platform-level adoption will generate downstream network effects.

Conclusion

The UA EWG guidelines provide a solid strategic baseline. Strengthening them through clear incentives, measurable outcomes, and ecosystem-level coordination mechanisms will be critical to ensuring that UA adoption translates into meaningful, globally inclusive Internet functionality.

This submission supports the UA Expert Working Group’s effort to develop structured, multistakeholder guidelines for advancing Universal Acceptance (UA), recognizing UA as a critical enabler of digital inclusion and a prerequisite for the effective expansion of the DNS, including the New gTLD Program: 2026 Round.

At a high level, the submission finds the guidelines comprehensive but recommends strengthening them in three key areas: incentives, implementation coordination, and outcome measurement. First, it highlights the need for clearer incentive and accountability mechanisms—such as UA readiness benchmarks, certification models, and procurement-linked requirements—to drive adoption among major platforms, software vendors, and service providers.

Second, the submission identifies fragmentation of implementation responsibility as a core challenge and recommends prioritizing developer-focused interventions, including standardized testbeds, reference implementations, and tooling support, to address persistent gaps in real-world deployment.

Third, while supporting the proposed measurement framework, the submission calls for a shift toward outcome-oriented metrics, such as platform-level UA compliance, public sector adoption rates, and measurable reductions in validation failures for internationalized domain names and email addresses.

In terms of prioritization, the submission recommends a layered implementation strategy, beginning with core infrastructure and platform readiness, followed by developer ecosystem enablement, policy integration, and capacity building.

Overall, the submission endorses the direction of the guidelines while emphasizing that scalable adoption will depend on measurable outcomes, ecosystem coordination, and stronger alignment with broader Internet governance and digital public infrastructure frameworks.