The UA Expert Working Group has produced exceptionally comprehensive guidelines for Universal Acceptance adoption. This comment offers constructive recommendations on stakeholder coverage, governance structure, and implementation framework to strengthen success while maximizing the exceptional expertise already assembled.

Strategic Assessment of the Guidelines

Strengths:

Comprehensive scope covering the entire ecosystem (technical, policy, social, economic)

Multi-stakeholder alignment with ICANN's core model

Evidence-based approach with clear measurement framework

Practical and actionable rather than purely aspirational

Acknowledges dependencies (chicken-and-egg problems, internationalization stack)

Critical Gaps for ICANN Board level Adoption:

1. Missing: Governance and Accountability Structure

Who owns implementation within ICANN org?

How does this integrate with existing ICANN structures (SOs, ACs, supporting organizations)?

What authority and role does this Expert Group have post-publication?

2. Missing: Risk Analysis

What if major platforms don't adopt despite efforts?

What if adoption creates new security vectors?

What if regional fragmentation occurs rather than global standardization?

4. Missing: Integration with Existing ICANN Strategic Initiatives

How does this connect to New gTLD 2026 Round success metrics?

How does this support SSR (Security, Stability, Resiliency)?

How does this advance ICANN's digital inclusion goals measurably?

2. Recommended Governance Structure for Implementation

Recognizing Exceptional Expertise Assembled

The Expert Working Group represents extraordinary assembly of global expertise industry leaders, standards authorities, government representatives, and academic thought leaders. This caliber of expertise is rare and invaluable. For ICANN's FY26-30 Strategic Plan success, particularly regarding digital inclusion and the New gTLD 2026 Round, continuing engagement with these specific experts over the 5-year implementation horizon is critical. Their institutional knowledge, networks, and authority cannot be easily replicated.

Current Structure Considerations for Implementation

The current structure served well for guideline development. For implementation phase, streamlined governance enhances execution efficiency direct ICANN CEO leadership provides clearer authority.

Recommended: ICANN CEO-Led 10-Member Expert Council

Governance Framework:

ICANN Board : Strategic oversight and CEO accountability. Budget and resource approval and Evaluates outcomes (does not direct operations)

    ↓

ICANN CEO (Chair) L Sole leadership authority, Strategic decision-making, Executive stakeholder engagement and Board reporting

    ↓

10-Member Expert Council : Domain expertise and advice, Execution in respective areas, Independent from Board and 5-year commitment aligned with Strategic Plan

    ↓

ICANN Organization : Professional staff support, Operations and logistics and Progress tracking

Recommended Composition (10 Members):

Continuing with the exceptional experts already assembled:

Edmon Chung (ALAC) - End-User Perspective and At-Large Community

Sami Mohamed Ali (ccNSO) - ccTLD Community and Government Connections

Abdalmonem Tharwat Galila (GAC) - Government Policy and Regulatory Frameworks

Nitin Walia (GNSO) - DNS Industry, registries, registrars, infrastructure

Nabil Benamar (SSAC) - Security and Technical Advisory

Representatives of (UNESCO) - Intergovernmental Organizations and Multilateral Policy

Sean Bedford (Meta) - Big Tech/Platform Leadership

Cathy Wissink (Unicode Consortium) - International Standards Authority

Richard Ishida (W3C) - Web Standards and Developer Ecosystem

Jiankang Yao (CNNIC) - Asia-Pacific Leadership and Major Markets

Thomas Mullaney (Stanford University) - Academic Integration and Research

Structural Refinements:

CEO chairs directly (no co-chair layer)

Board oversight separated from expert advice (no Board liaison)

ICANN org staff provides support without leadership roles

Result: Clear authority, no conflicts, efficient coordination

Why These Specific Experts for 5-Year Implementation:

The Expert Group should not "report and dissolve." They should become the founding core of a global movement that outlasts their tenure and ultimately makes Universal Acceptance so universal that the term itself becomes obsolete. Each brings irreplaceable value. Selected after process and nominated with trust. These individuals collectively represent access to billions of users, hundreds of governments, thousands of organizations, and the institutions that set global standards. Maintaining their sustained engagement over the 5-year Strategic Plan period is essential for achieving ICANN's UA adoption goals.

Key Advantages:

Clear authority: CEO decides, experts execute in domains, staff supports

No conflicts: Board oversees independently; experts advise without conflicts

Sustained expertise: Same experts through full 5-year implementation

Comprehensive coverage: All critical stakeholders represented

Efficient coordination: 10 members optimal for CEO personal leadership

Authentic representation: SO/AC members fully empowered in constituency roles

3. Resource Planning and Prioritization

Resource Specification Needed: The 45 guidelines lack budget and staffing estimates. Recommendation: Publish resource requirements for implementation tiers enabling informed Board decisions.

Suggested Framework:

Years 1-3: $3-5M annually for foundation

UA Program Office with professional staff

Regional coordinators supporting expert activities (5)

Technical tool development and maintenance

Training programs and capacity building

Measurement infrastructure and reporting

Phased Implementation:

Phase 1 (0-12 months) - Foundation:

Define UA-readiness comprehensively (Guideline 1)

Baseline standards promotion (Guideline 13)

DNS industry systematic engagement (Guidelines 22-26)

Measurement baseline establishment (Guidelines 42-45)

ICANN systems 100% UA-ready (organizational leadership)

Phase 2 (12-24 months) - Ecosystem Development:

Open-source application priorities (Guidelines 8-12)

Big tech business case development (Guidelines 3-7)

Developer capacity building (Guidelines 16-19)

Public sector engagement via IGOs (Guidelines 31-35)

Phase 3 (24+ months) - Sustainable Transformation:

Academic curriculum integration (Guidelines 36-41)

Standards organization contribution (Guidelines 14-15)

System administrator outreach (Guidelines 20-21)

4. Measurement and Accountability Framework

Baseline Establishment Priority: Year 1 must establish comprehensive baselines across awareness, policy, implementation, and capacity categories before scaling. Without baselines, progress assessment remains impossible.

Indicator Enhancements:

Leading indicators: Supplement outcome metrics with commitments secured and projects initiated

Third-party validation: Independent verification for critical claims (platform readiness, DNS industry compliance)

Public dashboard: Quarterly transparent progress reporting

Comparative metrics: Standardized methodologies enabling cross-regional and cross-sector comparison

Quarterly reporting: Regular updates from each expert on domain-specific progress

5. Integration with ICANN Strategic Priorities

New gTLD 2026 Round Integration: Strengthen explicit linkage:

Application requirements include demonstrated UA-ready systems

Registry Agreements specify UA compliance technical requirements

Pre-delegation testing validates UA functionality

Publish "New gTLD UA Readiness Requirements" by Q3 2026

FY26-30 Strategic Plan Alignment: Position UA adoption as measurable contribution to:

Digital inclusion objectives

DNS security and stability

Competition and consumer choice

Operational excellence

Multi-stakeholder model effectiveness.

**Other Comments Continued below:

Multi-Stakeholder Model Demonstration: SO/AC representatives (Edmon Chung, Sami Mohamed Ali, Nitin Walia, Nabil Benamar, Abdalmonem Tharwat Galila) drive their respective constituency engagement with transparent progress reporting, demonstrating model's effectiveness for complex global coordination.

6. Risk Management and Contingency Planning

Develop explicit mitigation strategies for:

Platform resistance: Contingency approaches if major platforms delay adoption

Coordination challenges: Breaking circular dependencies between infrastructure and applications

Security concerns: Addressing internationalization-related security challenges

Resource constraints: Prioritization framework if funding falls short

Expert availability: Ensuring sustained expert engagement over 5-year period

7. Long-Term Sustainability Beyond ICANN Coordination

5-Year Transition Model:

Years 1-3: ICANN-driven with expert execution

Years 4-5: Co-leadership with increasing expert network autonomy

Years 6-10: Expert networks self-sustaining with ICANN platform support

Years 10+: Market-driven compliance with ICANN monitoring

Expert Network Sustainability: Create independent value for expert engagement and UA expertise becomes valuable to help and guide community .

8. Community Consultation and Transparency

Regular Engagement Mechanisms:

Quarterly public progress reports from CEO

Annual community consultation on priorities

SO/AC regular updates from their representatives

Public metrics dashboard tracking progress

Case studies and success stories shared openly

Expert visibility at ICANN meetings and major forums

The UA Expert Working Group guidelines provide exceptional foundation for advancing Universal Acceptance. For implementation success, we recommend:

Address stakeholder gaps

Implement CEO-led 10-member governance with the specific experts assembled—their sustained engagement over the 5-year Strategic Plan period is critical to success

Commit adequate resources ($3-5M annually) with transparent planning

Phase implementation prioritizing foundation before scaling

Establish robust measurement with baselines, validation, and transparency

Integrate with strategic priorities (new gTLD requirements, FY26-30 goals)

Plan risk management with contingencies for key challenges

Design for sustainability enabling ecosystem independence long-term

The streamlined governance structure—CEO-led, Board-accountable, conflict-free—optimizes the exceptional expertise already assembled. These ten experts collectively provide access to billions of users, hundreds of governments, major technology platforms, international standards bodies, and academic institutions worldwide. Their continued engagement through full 5-year implementation is essential—this expertise cannot be easily replicated and represents ICANN's strategic asset for achieving UA adoption goals.

This represents historic opportunity to enable billions to express digital identity in native languages. The expertise is assembled, the guidelines are comprehensive, and the path forward is clear. With recommended enhancements and sustained commitment to these experts' leadership, UA adoption can become ICANN's signature achievement in digital inclusion and a demonstration of multi-stakeholder model effectiveness for complex global challenges.

The community appreciates the Expert Working Group's exceptional dedication to this critical work and supports implementation of these important guidelines with the governance enhancements recommended.