Advisory: Clarifications to the 2013 Registrar Accreditation Agreement (RAA) Whois Accuracy Specification
Publication Date: 16 November 2015
During a review of the Whois Accuracy Program Specification of the 2013 Registrar Accreditation Agreement (the "Specification"), ICANN and the Registrar Stakeholder Group agreed that it would be helpful to clarify or define some of the terms in the Specification. This Advisory seeks to provide those clarifications and definitions, as follows:
- Where they appear in the Specification, the words "validate" and "validation" refer to the process by which a registrar confirms that the format of data is consistent with standards, as described in section 1(a)-1(e) of the Specification.
- Where they appear in the Specification, the words "verify" and "verification" refer to the process by which a registrar confirms or corrects the accuracy of data by contacting and receiving an affirmative response from a point of contact, as described in section 1(f) of the Specification.
- For avoidance of doubt, a registrar is not required to validate or verify Registered Name Holder (and, if different, Account Holder) contact information when a Registered Name is renewed solely because the registration renewed. (If contact information is materially changed or if another circumstance requiring validation or verification applies, such as those identified in section 4 of the Specification, the registrar must perform the required action(s).)
- In cases where a registration is transferred to a gaining registrar, and in the course of the transfer, the gaining registrar obtains consent to the transfer via the Form of Authorization from the Registered Name Holder or Account Holder via means that would fulfill the verification requirements of section 1(f)(i) of the Specification, the gaining registrar does not need to repeat the verification process on the contact data if there are no material changes to that contact data.
- Whois-related complaints that are processed by ICANN as a "data format" issues (as opposed to "data accuracy" issues) do not invoke an obligation for the registrar to validate or verify Whois information. Examples of "data format" issues include a missing country code for a telephone number (as long as the number otherwise contains the proper number of digits for that country) or an email address that is written with "(at)" instead of "@." In such cases, the registrar is required to correct the data formatting issue but is not required to contact the Registered Name Holder to verify the formatting correction.
- For avoidance of doubt, registrars are permitted to engage third parties (e.g. Resellers) to perform data validation and verification as required under sections 1, 2, 4, and 5 of the Specification, but registrars, as the signatories to the RAA, are ultimately responsible for ensuring compliance with the Specification's requirements.