ICANN Support for Registrants and Those Impacted by Net 4 India Limited
In April 2019, the ICANN organization (org) became aware of the insolvency proceedings commenced against the registrar Net 4 India Limited (IANA 1007), located in India. In response, ICANN org has been taking actions to protect registrants. These actions include enforcing applicable contractual obligations against Net 4 India Limited, and providing information to registrants seeking guidance. Over the past few months, ICANN org has received complaints concerning Net 4 India Limited's unresponsiveness to transfer and renewal requests and registrant-provided updates to WHOIS registration data. ICANN org has also observed registrant confusion in many instances in which Net 4 India Limited acts as a reseller for another registrar, Hosting Concepts B.V. doing business as Openprovider.
This blog highlights resources available for registrants experiencing issues with their domain name registrations with Net 4 India Limited and explains actions ICANN org is taking to ensure this registrar complies with its contractual obligations.
ICANN Assistance to Registrants and Affected Users
ICANN org has been providing, and will continue to provide, direct assistance to the affected registrants and users through various avenues. ICANN's Global Support Center, as well as our Head of India, Samiran Gupta, have been providing email and telephone assistance to registrants seeking guidance and information. ICANN Contractual Compliance has also been providing clarifications and additional information to complainants.
We also invite registrants who believe their rights are not being observed by their registrar and those affected by such actions to use these links to learn more about:
- Domain Name Registrants
- Contractual Compliance
- Global Support Center
- ICANN Learn – An online learning platform requested by and built for the global ICANN community.
Information and Resource Links: When, How, and Where to File a Complaint
Registrants have the right to transfer second-level domain name registrations in generic top-level domain (gTLD) names between registrars, renew expired registrations, update their registration data, and transfer their registration rights to other registrants. ICANN-accredited registrars must provide these services in accordance with the requirements of the Registrar Accreditation Agreement (RAA), the Transfer Policy, the Expired Registration Recovery Policy, and the Expired Domain Deletion Policy. Registrants who believe that these rights are not being observed by their registrar are encouraged to review the following information:
- How to transfer a domain name is available here.
- If you have contacted the registrar and are unable to obtain the AuthInfo code(s) and/or unlock the domain name(s) for transfers, you may submit a complaint to ICANN Contractual Compliance through this form.
- How to renew a domain name is available here.
- If your domain has expired and you have contacted Net 4 India Limited to renew without success, you can submit a complaint to ICANN Contractual Compliance through this form.
- If you are not receiving assistance with updating registrant information, you may submit a complaint through this form.
- All forms to submit complaints to ICANN Contractual Compliance can be found here.
- ICANN org's resource hub for registrants is available here.
More Information on Submitting a Complaint to ICANN Contractual Compliance
Before submitting a complaint, please confirm that the domain name is registered with Net 4 India Limited or Openprovider, as Net 4 India Limited also acts as a reseller for Openprovider. You can check the publicly available registration information for the domain name to verify your registrar here. If the registrar is Openprovider, please contact this registrar directly for assistance. Openprovider is responsible for the compliant provision of registrar services done through its reseller. If Openprovider does not address your issue, you may submit a complaint to ICANN Contractual Compliance using the links referenced above.
Please also confirm your complaint refers to a domain name in a gTLD and not in a country code top-level domain (ccTLD). ICANN org does not accredit registrars or set policy for ccTLDs (such as .IN). For inquiries and issues involving ccTLDs, you can contact the relevant ccTLD manager using the contact details at https://www.iana.org/domains/root/db.
Ensure your complaint to ICANN Contractual Compliance includes:
- All affected domain names.
- Evidence that you are the registrant for all domain names relevant to your complaint (e.g., screenshots of the control panel showing the domain name and your details as the registrant).
- Evidence of being authorized by the registrant(s) to act on their behalf if you are not the registrant or are acting on behalf of the registrant organization.
- Evidence of having contacted the registrar for assistance. ICANN Contractual Compliance cannot address a complaint unless and until the registrant has first attempted to ask the registrar to resolve the registrant's issue. This information is requested in the complaint forms, please ensure you include it.
Enforcement of ICANN Agreements and Policies Related to Net 4 India Limited
Upon learning of the insolvency resolution proceedings against Net 4 India Limited, ICANN org initiated and continues to take extensive efforts to assess and take actions to protect registrants.
As part of these efforts, ICANN Contractual Compliance initiated daily monitoring of complaints submitted by registrants against Net 4 India Limited. Obligations such as making data escrow deposits or other circumstances affecting registrants (e.g., website operability) were, and continue to be, routinely verified.
On 23 April 2019, ICANN Contractual Compliance sent an Escalated Notice to Net 4 India Limited that resulted in the 5 June 2019 Notice of Suspension (Notice). The Notice suspended Net 4 India Limited's ability to register or initiate inbound transfers of domain names for 90 days. The Notice also requested Net 4 India take certain actions to maintain its accreditation with ICANN org. The suspension was to be effective from 21 June 2019 through 18 September 2019 (Suspension Period), or longer if Net 4 India Limited failed to take the actions specified in the Notice.
On 20 June 2019, ICANN org postponed the start date of the Suspension Period after considering information regarding the insolvency proceedings. Nevertheless, the related Notice with the RAA violations and its cure requirements were maintained. The court-appointed resolution professional for Net 4 India Limited was required to provide regular updates on the status of the proceedings, while ICANN org's efforts to protect registrants continued. During these updates, the resolution professional provided ICANN org with information related to the progress of the proceedings in India. In response, and because the registrar appeared to continue to provide registrar services, ICANN granted extensions to the Notice's deadline.
Since the issuance of the 5 June 2019 Notice through 30 September 2020, ICANN Contractual Compliance received more than 400 complaints against Net 4 India Limited. This number includes complaints submitted by registrants, by third parties (e.g., WHOIS inaccuracy or abuse complaints), and those resulting from ICANN org's own monitoring. Of those more than 400 complaints, just over 70 percent, were received in August and September 2020. Approximately 74 percent of the complaints received between 5 June 2019 and 30 September 2020 have been closed because the issue (which in many cases involved several domain names) was resolved, or the complaint was out-of-scope (e.g., duplicate of a complaint already in process). ICANN Contractual Compliance continues addressing the complaints that remain open, as well as complaints received after 30 September 2020.
ICANN org has continued its monitoring and enforcement activities undertaken within the frame of the Notice of Suspension. Additionally, in response to complaints alleging violations of the RAA and consensus policies, ICANN Contractual Compliance requires the registrar to demonstrate compliance with the relevant contractual obligations. Many but not all of these complaints have been resolved. ICANN Contractual Compliance continues to address those that remain outstanding as well as new ones as they are submitted.
Current Status and What Could Happen Next
Based on information available to ICANN org through complaint handling, monitoring activities, and updates from the court-appointed resolution professional, the registrar appears to continue operations as of the date of this blog. ICANN org continues to monitor the registrar's performance with respect to its RAA obligations and may terminate the registrar's RAA if Net 4 India Limited is unable to become compliant with the RAA requirements.
If ICANN org terminates the registrar's RAA, it would invoke the De-Accredited Registrar Transition Procedure to protect registrants and enable the transition of the domain names under management of the terminating registrar to an ICANN-accredited registrar. Once a gaining registrar is identified and confirmed, it would then be listed on the Bulk Transfers page.
Certain registry operators have elected to terminate their Registry-Registrar Agreement with Net 4 India Limited, meaning that the registrar is no longer authorized to register domain names under certain gTLDs. Affected domain name registrations are being transferred to registrars that are authorized to sponsor the domain names by the registry operators of the relevant gTLDs.
ICANN org will continue to monitor the situation closely and take actions to protect registrants' rights where the registrar fails to become compliant with its RAA obligations.