The Internet Service Providers and Connectivity Providers Constituency (ISPCP) appreciates the opportunity to provide input on the draft Guidelines for Advancing Universal Acceptance (UA) Adoption.

ISPCP broadly supports the direction and structure of the draft and commends the UA Expert Working Group (UA EWG) for developing a comprehensive and well-considered framework. The document reflects a strong understanding of the technical layers, stakeholder diversity, and the practical challenges associated with UA adoption.

At the same time, ISPCP would like to highlight a few areas where further strengthening would significantly improve the effectiveness and implementability of the guidelines.

First, the current draft does not sufficiently address the growing role of Artificial Intelligence (AI) systems in the internet ecosystem. AI is increasingly involved in generating, validating, and processing domain names and email addresses. If these systems are not UA-ready, they risk reinforcing existing limitations at scale. ISPCP recommends recognizing AI systems as a distinct stakeholder category and incorporating targeted guidance for AI model training, AI-driven email systems, code generation tools, and conversational interfaces.

Second, while the guidelines outline important areas of action, they would benefit from the inclusion of clearer implementation mechanisms. In particular, defining time-bound targets, phased adoption approaches, and measurable indicators will help translate the guidelines into actionable outcomes. Establishing baseline measurements and tracking progress through structured reporting will be critical to demonstrating impact.

Third, ISPCP notes that the guidance related to ISPs and hosting providers would benefit from further operational depth. As entities managing core internet infrastructure, ISPs face practical constraints such as legacy systems, operational risk, and evolving security frameworks. Addressing these realities through reference architectures, pilot programs, and targeted engagement will be essential to enable adoption at scale.

In addition, ISPCP emphasizes the importance of ecosystem development. There is currently a limited pool of organizations and solution providers capable of supporting UA readiness. Encouraging capacity building, enabling technical support structures, and fostering a broader ecosystem will reduce barriers for adoption, particularly in developing regions.

ISPCP also recommends strengthening the focus on public awareness and government engagement. Large-scale adoption of UA will depend not only on technical readiness but also on policy support, procurement frameworks, and broader digital inclusion initiatives.

Finally, ISPCP underscores the importance of a clear implementation and governance framework. Defining roles, responsibilities, and coordination mechanisms within ICANN, along with an ongoing role for the UA EWG in guidance, alignment, and monitoring, will be key to ensuring sustained progress.

ISPCP remains committed to supporting UA adoption and looks forward to continued collaboration with ICANN org and the broader community.

This submission provides detailed input from the Internet Service Providers and Connectivity Providers Constituency (ISPCP) on the draft Guidelines for Advancing Universal Acceptance (UA) Adoption.

The attached document expands on ISPCP’s perspective as an infrastructure-focused stakeholder, highlighting both support for the overall framework and recommendations to strengthen its practical implementation.

Key contributions include:

- Identification of Artificial Intelligence (AI) systems as a critical and currently underrepresented stakeholder category, with proposed guidelines addressing AI model behavior, email systems, and code generation tools.

- Detailed operational input on hosting providers and ISPs, including recommendations on reference architectures, pilot programs, resolver readiness, and email system considerations.

- Suggested enhancements to the measurement framework, including ISP-specific and AI-specific indicators to enable more accurate tracking of UA adoption.

- Recommendations for time-bound targets, phased implementation, and measurable benchmarks to improve accountability.

- Emphasis on ecosystem development, including the need to support UA-ready service providers and capacity-building initiatives.

- Input on public sector engagement, procurement frameworks, and digital inclusion.

- A proposed implementation and governance framework outlining roles, coordination mechanisms, and monitoring approaches, including the role of the UA Expert Working Group.

The submission is intended to complement the draft guidelines by adding operational depth, implementation clarity, and cross-stakeholder coordination considerations.

The Internet Service Providers and Connectivity Providers Constituency (ISPCP) supports the draft Guidelines for Advancing Universal Acceptance (UA) Adoption and recognizes them as a comprehensive and well-structured foundation for advancing UA globally.

ISPCP’s submission focuses on strengthening the guidelines to improve their practical implementation and impact.

Key recommendations include:

- Introducing Artificial Intelligence (AI) systems as a dedicated stakeholder category, recognizing their growing role in handling domain names and email addresses.

- Enhancing guidance for ISPs and hosting providers by incorporating operational realities, including legacy infrastructure, email systems, and resolver behavior.

- Defining time-bound targets, phased implementation approaches, and measurable indicators to support accountability and progress tracking.

- Expanding the measurement framework to include ISP-specific and AI-specific metrics.

- Promoting ecosystem development to increase the availability of UA-ready solutions and service providers.

- Strengthening public sector engagement, awareness efforts, and procurement-driven adoption.

- Establishing a clear implementation and governance framework within ICANN, including coordination, monitoring, and the continued role of the UA Expert Working Group.

ISPCP believes these enhancements will help translate the guidelines into actionable outcomes and accelerate UA adoption across the global internet ecosystem.