Purpose: This public comment proceeding seeks input from the community on the proposed revised Registry Registration Data Directory Services Consistent Labeling and Display Policy (“Policy”). The proposed revisions to the Policy address community feedback on the requirement in the Policy for registries to implement a Registration Data Access Protocol (RDAP) service in order to achieve consistent labeling and display of registration data. This requirement has been removed from the version of the proposed Policy being posted for comment.
Current Status: The Policy Implementation Review Team and ICANN have developed a revised version of the Policy. Provision 12 of the Policy, published on 26 July 2016, states: “The implementation of an RDAP service in accordance with the "RDAP Operational Profile for gTLD Registries and Registrars" is required for all gTLD registries in order to achieve consistent labeling and display.”
In August 2016, the Registry Stakeholder Group (RySG) submitted a Request for Reconsideration regarding the recently published CL&D Policy. The RySG asserted that the scope of the Policy was improperly expanded to include requirement for registiries to implement RDAP.
Next Steps: ICANN will prepare a Public Comment Summary and Analysis Report at the conclusion of the comment period. ICANN will review the comments received in collaboration with the Implementation Review Team (IRT) to determine whether any changes need to be made to the revised proposed implementation as a result of the input received.
Separately, ICANN intends to request that registries implement RDAP pursuant to the terms of their registry agreements.
Section I: Description and Explanation
On 7 February 2014, the ICANN Board adopted GNSO consensus policy recommendations regarding the use of “thick” Whois by all gTLD registries. In consultation with the GNSO Implementation Review Team (IRT), which was formed as directed by the GNSO Council to work with ICANN staff to ensure that the resultant implementation fulfills the intentions of the approved policy recommendations, ICANN staff has identified two expected outcomes in the PDP recommendations:
- The consistent labeling and display of Whois output for all gTLDs (originating from Recommendation #1)
- The transition from thick to thick for .COM, .NET and .JOBS (originating from Recommendations #1 and Recommendation #3)
In order to guide the implementation of Recommendation #1, ICANN in collaboration with the IRT took the following steps:
- Conducted an Impact Assessment and Detailed Analysis of the Consistent Labeling and Display requirement for all gTLDs
- Proposed a synchronized implementation of this requirement with the roll out of RDAP in order to minimize impact on affected parties by allowing potential economies of scale in development efforts
- Proposed a phased approach to the implementation in order to synchronize implementation with work ongoing at the IETF on EPP Extensions that are necessary for part of this implementation
- Created a Draft Thick RDDS (Whois) Consensus Policy and relevant Implementation Notes, which address implementation of the consistent labeling and display outcome.
On 3 December 2015, ICANN posted the Proposed Implementation of GNSO Thick Whois Consensus Policy Requiring Consistent Labeling and Display of RDDS (Whois) Output for All gTLDs for public comment. Based on the comments received, ICANN published the Registry Registration Data Directory Services Consistent Labeling and Display Policy (“Policy”) on 26 July 2016 and notified registries of the effective date to implement the Policy.
On 9 August 2016, the Registry Stakeholder Group (RySG) submitted a Request for Reconsideration regarding the Policy, objecting to the inclusion of RDAP as part of the Consensus Policy. The RySG asserted that the scope of the Policy was improperly expanded to include requirement for registiries to implement RDAP.
ICANN worked with the Implementation Review Team to address this matter, and ICANN is now posting a draft revised CL&D Policy [PDF, 168 KB] for public comment. The revised draft proposes to delete provision 12, which states that, “The implementation of an RDAP service in accordance with the "RDAP Operational Profile for gTLD Registries and Registrars" is required for all gTLD registries in order to achieve consistent labeling and display”.
ICANN intends to request that registries implement RDAP pursuant to the terms of their registry agreements.
Section II: Background
ICANN specifies Whois service requirements through Registry Agreements (RAs) and the Registrar Accreditation Agreement (RAA) for the generic top-level domain (gTLD) registries. Registries have historically satisfied their Whois obligations under two different models. The two models are often characterized as “thin” and “thick” Whois registries.
This distinction is based on how two distinct sets of data are maintained. WHOIS contains two kinds of data about a domain name:
- one set of data is associated with the domain name itself (e.g., the sponsoring registrar, status of the registration, creation and expiration dates for each registration, name server data, the last time the record was updated in the Registry database, and the URL for the registrar’s Whois service),
- a second set of data that is associated with the registrant and other contacts of the domain name.
In a thin registration model the Registry only collects the information associated with the domain name from the Registrar. The Registry in turn publishes that information along with maintaining certain status information at the Registry level. Registrars maintain data associated with the registrant of the domain and provide it via their own Whois services, as required by Section 3.3 of the RAA for those domains they sponsor.
In a thick registration model the Registry collects both sets of data (domain name and registrant) from the Registrar and in turn publishes that data via Whois.
Section III: Relevant Resources
- Registry Registration Data Directory Services Consistent Labeling & Display Policy (Rescinded implementation documents posted on 26 July 2016)
- Request for Reconsideration submitted by RySG on 9 August 2016
- Proposed Revised Registry Registration Data Directory Services Consistent Labeling and Display Policy [PDF, 168 KB]