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: Sarah Wyld
Date: 23 Feb 2026
Affiliation: Registrar Stakeholder Group (RrSG)
Preliminary Recommendation 1
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The clear establishment of guidelines pertaining to TLD sets and application processes is very helpful, and the RrSG supports the underpinning principle that a base ASCII gTLD is required to create a Latin Diacritic TLD set.

Preliminary Recommendation 39
Support Recommendation as written

Please provide your rationale and/or proposed changes:

The RrSG appreciates that this Working Group's recommendations align closely with that of the work of the EPDP on IDNs as documented in their Phase 1 and Phase 2 Final Reports, ensuring a level of consistency in Policy and process. Where there are clear deviancies from the workings of the EPDP on IDNs processes (such as behaviours at the second level in relation to variants outlined in Recommendation 39) providing a clear rationale is demonstrative of the level of knowledge and understanding of Working Group in making these differences clear and understandable. The consistency in approach is further witnessed through the continuation of the “same entity” principle and cost recovery principles from the 2026 Round AGB.

Preliminary Recommendation 51
Support Recommendation as written

Please provide your rationale and/or proposed changes:

We are mindful of the additional obligations initiated through the outcomes of the EPDP on IDNs Phase 2 Final Report work and referenced in the LD PDP Initial Report relating to the establishment of a mechanism to communicate between Registries and Registrars for the requesting of a “set” and the best efforts required in relation to ongoing full backward compatibility with delegated gTLDs. That said, we want to commend the efforts of the Working Group to demonstrate efficiency and timeliness without compromise of comprehensiveness in the creation, compilation and distribution of this Initial Report.

Do you agree with the LD PDP WG’s impact analysis on Global Public Interest (GPI)? If not, please provide details below.

With respect to the Global Public Interest checklist and Human Rights Impact Assessment, as the first PDP to conduct such an analysis, the RrSG applauds the efforts of this Working Group. The RrSG appreciates the comprehensive and thorough analyses and that the Working Group took the concerns raised in the assessments relating to human rights and diversity into consideration when drafting the Recommendations.

Do you agree with the LD PDP WG’s impact analysis on Human Rights (HR)? If not, please provide details below.

With respect to the Global Public Interest checklist and Human Rights Impact Assessment, as the first PDP to conduct such an analysis, the RrSG applauds the efforts of this Working Group. The RrSG appreciates the comprehensive and thorough analyses and that the Working Group took the concerns raised in the assessments relating to human rights and diversity into consideration when drafting the Recommendations.

Other Comments

The Registrar Stakeholder Group (“RrSG”) appreciates the opportunity to provide a comment on the Latin Script Diacritics PDP Initial Report (“LD PDP Initial Report”) and the LD PDP Working Group’s work on drafting this Initial Report. This is a significant undertaking by ICANN org and the ICANN community, and the RrSG appreciates the efforts and actions of the Working Group relating to this issue of diacritic and variant strings. 

The Registrar Stakeholder Group is the representative body of ICANN-accredited domain name registrars. Operating with numerous subgroups focused on specific topics of interest, the RrSG contributes to policy development, issue advocacy, and negotiations with ICANN. We work to advance the interests of registrars and our customers by promoting data-driven policy outcomes. Learn more about the RrSG on our website rrsg.org.