The GAC supports the two issues identified for Policy Development Processes (PDPs) in the Preliminary Charter – Unrestricted Application Programming Interface (API) access for high-volume registrations and Associated Domain Checks – and recommends that chartering of the PDP(s) be constructed in such a way that it prioritizes concrete results before the next round of generic Top-level domains (gTLDs).

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The Issue Report also identifies and explains a variety of additional “policy gaps” underlying DNS Abuse within ICANN’s remit. [...]. To the extent possible, the Issue Report should identify possible paths to address these gaps, whether through further policy development, or through non-binding efforts (e.g., sharing best practices) and cooperation between relevant communities.

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The Preliminary Charter packages two issues into one Policy Development Process [...]. The GAC recognizes the opinion that two separate PDPs, each with its own charter and a narrow scope, as opposed to one PDP with a broader scope, would better fit the expectation of targeted and narrowly scoped PDPs. The GAC favors the approach that has the most chances to “achieve results according to shorter timelines”2 and recommends gathering opinions from stakeholders during the upcoming ICANN meeting.

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Should sequencing be necessary, the GAC suggests beginning with Associated Domain Checks because its scope and charter questions appear to be narrower than those involved in the API issue. A narrower scope should lead to a more straightforward path for the ICANN community to consensus.

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To make the forthcoming PDPs more predictable, and to accelerate efforts on DNS Abuse mitigation, the final Charters should include a specific timeline for policy development and implementation and include milestones [...]

The full GAC Comment is available at: https://gac.icann.org/statement/public/gac-comments-dns-abuse-prelim-issue-report-18oct25.pdf