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Continued Operations Instrument (COI) Amendment Service Frequently Asked Questions

Please note that the English language version of all translated content and documents are the official versions and that translations in other languages are for informational purposes only.

Q1: What is the Continued Operations Instrument (COI) Amendment Service?

A1: The Continued Operations Instrument (COI) Amendment Service provides a method for Registry Operators (ROs) to request an amendment from ICANN to change the funding levels of their COI values up or down to better align with domain registrations under management (DUMs) of a top-level domain (TLD). The COI funds are an important part of safeguarding the operation of top-level domains (TLDs) by ensuring there are sufficient financial resources to protect the continuity of critical registry functions. If ICANN finds that a COI is insufficiently funded at any time after a gTLD has been delegated, the RO will be referred to the COI Amendment Service and have 60 days to amend their COI funding level. To request a COI amendment, download the COI Amendment Request Form [PDF, 1.04 MB] and submit via the GDD Portal.

Q2: Why would ROs amend their COI?

A2: In December 2011, ICANN published guidance to help ROs calculate the estimated costs of TLD operations based on projected DUMs. Since that time, the launch of new gTLDs has provided market-driven data points on which to base their projections. With the COI Amendment Service, ROs now have a mechanism to request a change to the value of their COI to align with the updated DUMs projections of a TLD.

Q3: What are the requirements to submit a COI Amendment request?

A3: The requirements are:

  1. The RO may request a COI Amendment if it is overfunded or insufficiently funded. This can be done any time after the registry has been in General Availability/Registration (GA) for six months as defined by the Claims Start Date.
    1. ROs must wait at least six months from the date a COI was previously amended before amending the same COI an additional time.
  2. The COI may be in the form of a Letter of Credit (LOC) or escrow agreement issued by the RO's bank.
  3. The Standard Emergency Event Fee Table attached to the Emergency Back-End Registry Operator (EBERO) Agreement [PDF, 1 MB] (Attachment D1) will be the guideline for calculating the appropriate value of a COI based on DUMs projections.
  4. COI Amendments must account for updated projections, not current DUMs.
    1. Projections must account for three years of operational expenses to support the five critical functions of the registry.
  5. In situations where one COI covers multiple TLDs, the total funds required will be determined by analyzing the DUMs against each respective TLD listed on the COI's allocation schedule.
  6. Requests for amendments will be evaluated against the most current submitted Monthly Transaction Report.
  7. All requests must be submitted via the GDD Portal and should use the COI Amendment Request Form [PDF, 1.04 MB]
  8. The RO is responsible for all banking fees associated with amendment, including, but not limited to:
    1. Advising fee(s)
    2. Amendment fee(s)

Q4: Does ICANN have an advising bank?

A4: Yes, Bank of America was selected as ICANN's advising bank through an extensive Request for Proposal (RFP) process. The institution is well-respected and has the expertise needed to ensure that these COIs meet all relevant financial regulations and requirements. They also maintain correspondence relationships with over 2,500 financial institutions globally. In addition, Bank of America has the infrastructure required to communicate securely with these banks and provide safekeeping services for all original documents. As Bank of America is ICANN's advising bank, all LOCs must be advised through Bank of America. Should Bank of America identify outstanding terms per their customary banking guidelines, ROs must amend such terms as part of the COI Amendment Service process.

Q5: Why did ICANN decide to outsource this function?

A5: Outsourcing this administrative function to an experienced financial institution allows ICANN to manage this process more effectively and focus on its core areas of expertise. Working with one designated advising bank will also allow ICANN to ensure that all COIs are executed in a consistent manner, properly authenticated and comply with standard global regulations.

Q6: What is the process?

A6: To initiate the process, the registry primary contact must complete and submit a COI Amendment Request Form [PDF, 1.04 MB] via the GDD Portal.

Once submitted, ICANN will perform a completeness check of the request to confirm it meets the requirements and is approved to move forward. If the COI is in the form of a LOC, ICANN will direct Bank of America, ICANN's advising bank, to work with the RO's issuing bank to make the required amendments. If the COI is in the form of an escrow agreement, ICANN will request the RO to work with the issuing bank to amend the escrow agreement. For a complete list of the steps, please read the How to Submit a COI Amendment Request [PDF, 282 KB].

Q7: How long does the process take?

A7: After a COI amendment has been requested, ICANN's service level target is to provide the RO with a response in five business days informing the RO if the request has been approved or denied. Once ICANN has approved the request, completion timing will vary depending on the RO and the bank, but could be finished in as quickly as 21 business days.

If the amendment request is due to a request from ICANN, the process for the COI Amendment Service should be completed within 60 calendar days.

Q8: Is the process the same in all regions?

A8: Yes, however, there may be delays in the timeline for some regions/countries due to differences in bank approval processes.

Q9: Is there any cost associated with the COI Amendment Service?

A9: Yes, there may be nominal banking fees associated with the service including, but not limited to, advising fees and amendment fees. 

Q10: Where can I go if I have additional questions?

A10: Please visit the Continued Operations Instrument (COI) page on Additionally, questions can be sent to ICANN Global Support:

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