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Contractual Compliance Monthly Update | October 2012

Table of Contents 1

Audit Program Update

As previously communicated, the ICANN audit program will run on a three-year cycle during which each registry and registrar agreement will be randomly selected for audit over a three-year period.

In an effort to increase transparency and readiness, please refer to the ICANN website, found by clicking: to access the documents listed below:

  • Registrar and Registry Audit Plans
  • Frequently Asked Questions (FAQ) document

Please send your questions to

Registrar Update

Responding to Whois Inaccuracy Complaints

As mentioned in September's update, application enhancements were completed to the Whois Data Problem Reporting System to align with the current contractual compliance process and improve processing quality and effort.

ICANN reviews and validates the "reasonable steps" taken by a registrar to address Whois inaccuracy complaints through its 1-2-3 notification process. The registrar must provide copies of the correspondence with the registered name holder while investigating the Whois inaccuracy claim or describe actions taken to be in compliance.

"Reasonable steps" will vary. At a minimum, registrar should:

  • Promptly transmit to the registrant "inaccuracy inquiries" by telephone, email, and postal mail
  • Update or correct Whois based on registrant feedback
  • Cancel the domain registration if the registered name holder:
    • Provided inaccurate or unreliable information
    • Failed to promptly update information
    • Failed to respond for over fifteen calendar days to inquiries

Domain Reseller Issues

The landscape of domain registration market has evolved over the last decade. With over 1,000 ICANN-accredited registrars located throughout the world, some provide domain registration services directly to the public and some through its reseller(s) or other intermediaries (resellers).

For ICANN-accredited registrars, domain names registered through a reseller could pose additional or unexpected compliance challenges.

Registrars are reminded that that the registrar of record shown in the gTLD registration data (i.e., Whois) is responsible for its reseller's action or inaction with regard to compliance issues arising from the Registration Accreditation Agreement (RAA).

Below is a list of some of the more common compliance issues:

  1. Reseller agreements between an ICANN-accredited registrar and its resellers do NOT include all of the provisions required by Section 3.12 of the RAA.
  2. Registration agreements do NOT include all of the provisions required by Section 3.7.7 of the RAA.
  3. Domain names registered to resellers as the registered name holder could lead to domain ownership/control, transfer and renewal or Whois inaccuracy issues.
  4. Resellers not maintaining required registration data and records.

To be compliant:

  1. The agreements between the ICANN-accredited registrar and its reseller(s) must include the same or equivalent language as in Section 3.12 of the RAA.
  2. All registration agreements between ICANN-accredited registrars and registered name holders and between resellers and registered name holders (resellers' customers) must include the same or equivalent language in Sections – of the RAA.
  3. Registrars should ensure their resellers obtain informed consent from their customers and are in compliance with any applicable laws (especially contract, data privacy laws and consumer protection laws) and regulations.
  4. Registrar must ensure that their resellers (as their agents) retain all the necessary data and records as required under Section 3.4.2 of the RAA. Registrars are reminded that ICANN may request copies of all written communications pursuant to section 3.4.3 of the RAA.

Complaints Handling and Enforcement Summary

This update is provided for information purposes only. Please exercise judgment in using the information contained within this update to make conclusions or business decisions based upon this update.

Complaints per Notification Cycle October 2012

Enforcement Activity for October 2012

Please refer to Contractual Compliance Notices for up-to-date information.

1This update is provided for information purposes only. Please exercise judgment in using the information contained within this update to make conclusions or business decisions based upon this update.

newsletter-oct12-en.pdf  [691 KB]

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."