Security Response Waiver (SRW) Requests for Registrars
The Security Response Waiver (SRW) service was developed to provide a process for ICANN- accredited registrars to inform ICANN organization of a present or imminent security incident (hereinafter referred to as "incident") to their registrar and/or the DNS. Using the SRW service, registrars can request a contractual waiver for actions it might take, or has taken, to mitigate or eliminate an incident. A contractual waiver is an exemption from compliance with a specific provision of the Registrar Accreditation Agreement (RAA) for the time period necessary to respond to the incident. The SRW has been designed to allow operational security to be maintained around an incident while keeping relevant parties (e.g., ICANN org, other affected providers) informed as appropriate.
In August 2021, ICANN org expanded the Expedited Registry Security Response (ERSR) process to enable registrars to submit waiver requests. As a result, the ERSR was renamed the "Security Response Waiver (SRW)".
A registrar may request this service when one or more of the following incidents occur:
- A malicious activity involving the DNS of such scale and severity that it threatens systematic security, stability, and resiliency of a gTLD or the DNS;
- An occurrence with the potential to cause a temporary or long-term threat impacting the registration of domain names at an ICANN-accredited registrar;
- A court order from a law enforcement agency with jurisdiction over the registrar which requires the registrar to take action due to a specific security threat.
Registrar SRW Process
ICANN org recognizes registrars may be required to take immediate action to prevent or address an incident in some instances due to extraordinary circumstances. In such cases, registrars should submit an SRW request as soon as possible so that ICANN org may respond with a retroactive waiver if appropriate.
There are three phases in the SRW process.
- Indicate whether action has already been taken.
- Indicate if action is urgent and the waiver is required prior to taking action.
- Provide a description of the incident and details on how the registrar plans to respond, or has responded to, the incident.
- Include the provisions the registrar is requesting to waive. This may include, but is not limited to, a temporary waiver for Section 3.9.2 of the RAA, specifically the transaction-based fee.
- Review of SRW Request - ICANN org will review the SRW request and provide a response. ICANN org may request additional information, if necessary, to ensure a comprehensive review and consideration of the SRW request. The requestor will be asked to provide such information expeditiously. On a case-by-case basis, ICANN org may contact the registrar and/or an external authority (e.g., law enforcement agency, security researcher, etc.) to confirm the incident.
- Determination and Response - ICANN org will respond in writing within 15 calendar days of receipt of all required information with either (i) a waiver or retroactive waiver, if appropriate, (ii) an update to an existing waiver, (iii) a determination that the request is in scope of an existing waiver, or (iv) a determination that a waiver will not be granted, including rationale. If indicated within the submission that action is urgent and the waiver is required prior to taking action, registrars will receive an expedited response from ICANN org.
Following a response to an SRW, ICANN org, in collaboration with the affected registrar, may develop an After Action Report that may be made available to the community. If an After Action Report is to be published, ICANN org and the affected registrar will jointly review which sections of the SRW request and After Action Report should be redacted to ensure confidential and proprietary information is protected.