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
Timeline for Urgent Requests for Lawful Disclosure of Nonpublic Registration Data
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Submission Summary:
The comment supports the direction of concretising the language of the proposal, but calls for further specifications. It presents possible risks to vulnerable groups, civil society and businesses if the language remains vague. Specifically the provision of immediate harm to critical infrastructure is scrutinised. Utmost sensitivity is called for when tackling the subject of child abuse is called for, based on a recent real-life client scenari...
Submission Summary:
The RySG supports the language in the new proposed section 10.7. This language faithfully describes the compromise timeline to respond to urgent requests established by the IRT. The RySG supports the proposed definition of “Urgent Requests for lawful disclosure” as described in the new section 3.8. It matches our understanding of what has been agreed by the IRT. The RySG also supports the language of the proposed implementati...
Submission Summary:
A dedicated Policy Development Process (PDP) is required to address authentication for urgent disclosure requests because authentication is not a mere implementation detail, but a core policy issue with direct implications for fundamental rights, legal compliance, and contractual enforceability. The criteria based on which urgent requests should be submitted should be defined narrowly and succinctly not open to interpretation. At pr...
Submission Summary:
See Full GAC Comment at: https://gac.icann.org/statement/public/gac-comments-urgent-requests-timeline-15dec25.pdf
Submission Summary:
Though obtuse to the comment period, I believe that truly imminent-harm cases would be better served by a centralized, ICANN-operated “911/999-style” escalation desk than by imposing near-identical 24/7 operational expectations on every registrar. A single intake point could triage and validate claims, confirm the registrar-of-record, and route the request to the correct registrar or registry—or, where more appropriate, redirect the matter to ...
Submission Summary:
Namecheap, Inc. submits this comment in response to ICANN's Timeline for Urgent Requests for Lawful Disclosure of Nonpublic Registration Data. We believe that this policy work is unnecessary as there is no evidence of urgent requests not being timely actioned through existing legal and policy frameworks that registrars already follow outside of ICANN processes. Additionally, the proposed wording ignores the recommendation to use "business day"...
Submission Summary:
The IPC believes that an agreed definition for “Urgent Requests” already exists based on policy previously adopted. The addition of a capitalized reference to “Authenticated Requestor” appears to require new Consensus Policy work which the IPC believes entails unnecessary delay in responding to legitimate requests.
The IPC believes that the best way forward would be for the community to cooperate on a pilot program for authenticati...
Submission Summary:
Please find attached (PDF) the ALAC Statement on the Timeline for Urgent Requests for Lawful Disclosure of Nonpublic Registration Data. Ratification information is included on the cover page.
Kind Regards,
ICANN Policy Staff in support of the At-Large Community
Submission Summary:
Tucows welcomes the opportunity to comment on the Timeline for Urgent Requests for Lawful Disclosure of Nonpublic Registration Data. While the definition of “Urgent Requests" comes close to appropriately defining the circumstances in which this compressed timeline can be required, Tucows is concerned that necessary guardrails are not in place for the definition of Urgent or the limitations on who can make an Urgent request, the process for han...
Submission Summary:
The RrSG appreciates the work of the IRT and IPT and the opportunity to comment on this Timeline. The required response timeframe has been a sticking point because policy must permit sufficient time to properly consider the request, make a sound legal decision, and remain compliant with relevant privacy laws, while also respecting the time-sensitive nature of the situation.
The RrSG looks forward to appropriate assurances tha...
Submission Summary:
Stiftung Digitale Chancen supports the ongoing process to define a meaningful timeline for urgent requests with regard to the Registration Data Request Service (RDRS) and encourage all parties involved in this process to strive for a solution close to the position of the Governmental Advisory Committee (GAC), ICANN Board and Council. Against this backdrop, this timeline should reflect the urgency of the prevention of critical harm to life. The...
Submission Summary:
While we recognise the importance of addressing urgent threats, the proposed timeline and definitions must be refined to prevent misuse and ensure compliance with data protection principles. We urge ICANN to revisit these definitions and incorporate the necessary safeguards to balance the needs of law enforcement with the rights of data subjects and the operational realities of registrars.