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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Submissions for this Proceeding
Registration Data Request Service (RDRS) Policy Alignment Analysis
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Submission Summary:
The gTLD Registries Stakeholder Group (RySG) appreciates the Board’s initiative in requesting this comprehensive policy alignment analysis and looks forward to receiving further details on what the Board considers the next steps. In its comment, the RySG focuses on the items of direct relevance to registry operators.
Submission Summary:
The NCSG supports the continued operation of the RDRS beyond the pilot phase, but this extension must be conditioned on meaningful improvements to transparency and accountability. The process for authenticating law enforcement and other requestors must also be clearly documented, publicly accessible, and subject to independent oversight.
Additionally, and to reiterate prior NCSG
Submission Summary:
See full GAC Comment at https://gac.icann.org/statement/public/gac-comments-rdrs-policy-alignment-15dec25.pdf
The GAC welcomes the Registration Data Request Service (RDRS) Policy Alignment Analysis and generally endorses the Road Map for Aligning RDRS-Related Policies with the ICANN Boar...
Submission Summary:
The IPC strongly welcomes efforts to address the gaps identified in the analysis – including mandatory registrar participation, integration of privacy/proxy service data, clear timelines for urgent requests, accreditation of requestors, and system integration (API) – as well as additional gaps the IPC has observed during the RDRS pilot. We believe that closing these gaps is essential to the effectiveness of RDRS for requestors (including IP ri...
Submission Summary:
Tucows appreciates ICANN Org for their work in drafting this Alignment Analysis and welcomes the Analysis’ confirmation that policy must be developed through the ICANN multistakeholder process before it can be applicable to Contracted Parties. Tucows notes with significant concern that implementation of a cost-recovery process funded by billing requestors for their use of the RDRS is barely considered in the Analysis, but supports the Analysis...
Submission Summary:
The RrSG appreciates the work of ICANN Org in rafting this Analysis. The RrSG agrees with the Analysis that many of the potential outcomes considered do require further Policy work, specifically including the authentication of law enforcement users, a mandatory requirement to use the RDRS, and treatment of domains using a registrar's Affiliated Privacy service.
The RrSG is significantly concerned about the lack of considerati...
Submission Summary:
The Coalition for Online Accountability (COA) appreciates the opportunity to comment on the Registration Data Request Service (RDRS) Policy Alignment Analysis and wishes to express several serious concerns about the current operation of the RDRS.
COA’s mission is to promote online transparency and accountability by ensuring that WHOIS and related registration data remain accessible, accurate, and reliable for intellectual property rights...
Submission Summary:
INTA strongly supports making RDRS participation mandatory for all ICANN-accredited registrars to ensure a centralized and reliable system, requiring a Consensus Policy for enforcement. INTA has provided detailed feedback on the Registration Data Request System (RDRS) pilot in previous meetings and submissions. We have emphasized the need for improvements to enhance its effectiveness and usability for both requestors and registrars, with a f...
Submission Summary:
Overall Position: The submission strongly advocates for an RDRS policy framework that is globally equitable, predictable, and scalable while firmly embedding digital rights and considering the resource constraints and specific enforcement needs of the Global South, particularly Africa.
High-Level Observations & Recommendations:
Predictability and Enforcement: T...
Submission Summary:
The BC appreciates the opportunity to comment on the RDRS. While we recognize its value as a temporary routing tool, the system has not fully met its intended objectives. Low registrar participation, lack of standardized authentication, and inconsistent disclosure practices continue to limit its usefulness for business users who rely on timely and predictable access to registration data. The BC supports extending the RDRS while prioritizing im...
Submission Summary:
Stiftung Digitale Chancen suggests the following enhancements for the RDRS or a successor system:
· Make participation mandatory for gTLD registrars,
· Make participation mandatory for ccTLD registrars,
· Make participation mandatory for registrar-affiliated privacy/proxy service providers,
· &...
Submission Summary:
This comment provides individual observations aligned with Sections 3.1–3.7, 4, and 5 of the RDRS Policy Alignment Analysis, identifying operational and policy gaps, recommending coordination across PPSAI, Registration Data Policy, and SSAD efforts, and requesting clearer direction on the long-term successor system roadmap.
Submission Summary:
Papua New Guinea fully supports the draft GAC Comments on the Registration Data Request Service (RDRS) Policy Alignment Analysis. From the perspective of a developing Pacific nation—where the .pg ccTLD is currently managed by Papua New Guinea University of Technology, the government is standardizing the .gov.pg namespace, researching Protective DNS (PDNS) in collaboration with Australia, and developing a sovereign .pg governance frame...