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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:

  1. 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.
  2. 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.
  3. 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).)
  4. 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.
  5. 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.
  6. 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.
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."