Subject:   Amendment to the Proposed Draft of Paragraph 2.6 of the Governance Document for the Recognition, Maintenance, and Derecognition of Regional Internet Registries (“Governance Document”)

The Malaysian Communications and Multimedia Commission (“MCMC”) expresses its appreciation to the Address Supporting Organization (“ASO”) with the assistance of respective Regional Internet Registries (“RIR”) for the effort and thoughtful work of drafting this Governance Document.

In reviewing the proposed paragraph 2.6 of the Governance Document on Sub-Regional Registries, MCMC respectfully seeks to raise a concern and propose an amendment to the phrase “at its complete discretion”. From MCMC’s understanding, the said phrase appears to confer full discretionary power upon a RIR to establish and delegate number resources to one or more sub-regional registries, which include National Internet Registries (“NIR”).

In this regard, MCMC is concerned that the phrase “at its complete discretion” could be interpreted as granting one party the sole authority to make critical decisions over matters that may have significant implications for national Internet governance. It must be noted that such discretionary power is not available in the current Internet Coordination Policy-2 concerning the Criteria for Establishment of New Regional Internet Registries.

Importantly, this also raises concerns regarding the rights and standing of individual countries in establishing their own NIR on the basis of Internet coordination and sovereignty. In this context, countries and their Internet communities should have a meaningful voice in discussions about establishing an NIR within their territory. Allowing such a decision to rest entirely with the RIR, which has no formal representation from the countries, could unintentionally overlook national priorities, regulatory environments and the demand of local stakeholders. This is particularly important in the spirit of respecting national interests while maintaining the stability and integrity of the global Internet.

While MCMC acknowledges the RIRs’ operational responsibilities, it is proposed for the phrase “at its complete discretion” in paragraph 2.6 of the Governance Document to be reconsidered, by rephrasing or omitting the said phrase to better reflect a more collaborative and consultative approach. This would strengthen the legitimacy of any future sub-regional registry arrangements, uphold the values of community governance and promote fair representation for all affected stakeholders, including the Governments and Internet communities.

It is noted that MCMC, via a letter dated 30 May 2025 to the ASO and an intervention at the 83rd Internet Corporation for Assigned Names and Numbers Meeting (“ICANN83”), had previously highlighted this position. Furthermore, during the ICP-2 Review – RIR Governance Document Consultation held at the Asia Pacific Network Information Centre 60th Conference (“APNIC60”) in Da Nang, Vietnam, on 10 September 2025, MCMC reiterated its concerns and sought clarification on the rationale for including this phrase. MCMC also queried whether the panel agreed that the phrase confers full authority to the RIR. While one of the panel members concurs with this interpretation, there is no discussion as to why the phrase was included or drafted in such a manner.

Thank you. 

Subject:   Amendment to the Proposed Draft of Paragraph 2.6 of the Governance Document for the Recognition, Maintenance, and Derecognition of Regional Internet Registries (“Governance Document”)

It is proposed for the phrase “at its complete discretion” in paragraph 2.6 of the Governance Document to be reconsidered, by rephrasing or omitting the said phrase to better reflect a more collaborative and consultative approach. This would strengthen the legitimacy of any future sub-regional registry arrangements, uphold the values of community governance and promote fair representation for all affected stakeholders, including the Governments and Internet communities.