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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Marianne Georgelin
Date: 10 Jul 2025
Affiliation: Afnic
Email: [email protected]
Original Public Comment: Final Proceeding for Proposed Language for the Draft Next Round Applicant Guidebook (AGB)
1) Is the language in draft Module 1: The Applicant Journey consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
2) Is the language in draft Module 2: Application Submission consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

The section on "Conditional Evaluation" (2.3.2) lacks clarity. It is unclear at which point in the application process the applicant is required to pay these fees: Is it at the time of submitting the application, or later in the process? Furthermore, the explanation provided does not specify what happens if no additional evaluation is required after submission. Will ICANN refund the fees if no further analysis is necessary, or is it a non-refundable charge regardless of the evaluation outcome? These aspects should be clarified to ensure that applicants understand when and how to pay these fees, and under what circumstances they may be eligible for a refund. Regarding conditional evaluation and fees, there is a significant lack of clarity on the utility of the "conditional evaluation fees" for geoTLDs, especially considering the proposed amounts (between 18K€ and 25K€). First of all, these fees are very high and may discourage applications for geographic TLDs. We would like to draw attention to the fact that most of geographic TLD applications are for non-commercial purposes, or to serve a geographically limited community. Such TLDs are often managed by smaller registries and have more limited potential in terms of scale and revenue. Furthermore, the question of what these fees are meant to cover remains ambiguous. Our understanding is that all applications will have to go through the GNP (geographic name panel) review to establish whether an applicant falls into the geoTLD category or not. The Geographic Names Review section (6.5.3.2) provides that : “A Geographic Names Panel (GNP) will determine whether each applied-for gTLD string represents a Geographic Name, and verify the relevance and authenticity of the supporting documentation where necessary. The GNP will review all applications received, not only those where the applicant has noted its applied-for gTLD string as a Geographic Name” If this is the case, the cost of the GNP review should be bear by all applicants, not just geoTLDs. Additionally, we understand that the fee structure includes the review of the required documentation (from the relevant governments or public authorities), but it is important to note that the validation of this documentation is the responsibility of the authorities in the respective countries, not third parties mandated by ICANN. Only the public authorities involved or the relevant GAC members can assess this documentation, with no additional cost. In this context, the fees seem excessively high, and their purpose and application need to be clarified to avoid confusion and ensure fairness in the process for geographic TLD applicants. Regarding Community Priority Evaluation (CPE) : The application fees for community TLDs seem excessively high and may act as a deterrent for potential candidates. The current fee structure appears to be prohibitively expensive for many applicants who might be interested in pursuing a community TLD but find the costs unsustainable. This high fee could disproportionately affect smaller, non-commercial organizations or community-based groups that may not have the financial resources to cover such substantial costs. As a result, the fee structure risks excluding these applicants, which goes against the goal of fostering diversity and inclusion within the domain name space. This issue is particularly true for applicants who, despite having strong community backing and the potential for meaningful impact, are not eligible for the Applicant Support Program (ASP). It would be beneficial for ICANN to reconsider the fee amounts for community TLD applications to ensure that the process remains accessible to a wide range of potential applicants, especially those with limited financial means but significant community support and potential impact. Regarding Application Volume Refund (2.3.3.2) The AGB states that : "Applicants will be requested to indicate at the time of submission whether they want to receive a volume refund, should one be applicable. If the applicant does not select the option to receive a volume refund, it will be considered to have forfeited its ability to receive a volume refund". Applicant should not have to select the option in order to receive a volume refund. It should be applicable to all applicants “by default” otherwise some might miss out of forget to check the box while fulfilling their application. Regading the Refund section (2.3.3 ) The current refund process proposes a 65% refund on applicant fees in the event of early withdrawal (compared with 80% in 2012). This lower refund is not clearly justified, especially considering the minimal processing of applications at the start of the pre-evaluation process (administrative checks only). The impact on applicants is significant. They stand to lose up to $80,000 between the first two refund periods, without any particular benefit, which is particularly problematic for small applicants. The application fee refund schedule should be structured more equitably particularly for unsuccessful applicants or those who withdraw their applications due to special circumstances.

3) Is the language in draft Module 3: Community Input, Objections, and Appeals consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
4) Is the language in draft Module 4: Contention Set Resolution consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
5) Is the language in draft Module 5: Applicant Evaluation Procedures consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
6) Is the language in draft Module 6: String and Application Evaluation Procedures consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

Please see our comment on Module 2

7) Is the language in draft Module 7: General Information consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
8) Is the language in draft Appendix 1: Application Questions consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
9) Is the language in draft Appendix 2: Materials related to Geographic Names consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

Please see our comment on Module 2

10) Is the language in draft Appendix 3: Objection and Appeal Materials consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
11) Is the language in draft Appendix 5: Templates for Standard Financial Profile consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
12) Is the language in draft Appendix 6: Predictability Framework consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
13) Is the language in draft Appendix 7: Conflict of Interest Process for Service Providers consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
14) Is the language in draft Appendix 8: Code of Conduct and Conflict of Interest Guidelines for Service Providers consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
15) Is the language in draft Appendix 9: New gTLD Program: Next Round Privacy Policy consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes
16) Is the language in draft Appendix 10: Terms and Conditions consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
Yes