The Non-Commercial Stakeholder Group (NCSG) welcomes the draft ICANN Office of the Ombuds Framework as a positive step toward greater transparency but stresses that key areas must be strengthened for the Office to serve as a credible, accessible, and rights-compatible accountability mechanism. The group emphasizes that grievance processes should align with the UN Guiding Principles on Business and Human Rights, including legitimacy, accessibility, predictability, equitability, transparency, rights-compatibility, and continuous learning.

NCSG identifies five main areas for improvement. First, independence and governance: requiring Board Leadership Team approval before initiating “Own Initiative Investigations” risks constraining the Ombuds’ ability to address systemic issues. The group recommends replacing prior approval with a notification-and-safeguards model, strengthening independence through community involvement in appointments, and ensuring protection from interference or retaliation. Second, accessibility and equity: the framework does not sufficiently address structural barriers such as language limitations, resource disparities, cultural differences, and fear of retaliation. NCSG calls for low-barrier intake, multilingual support, accessible formats, safe-contact options, and emergency procedures for time-sensitive digital rights matters. Third, transparency and accountability: broad discretion over whether to publish findings may limit institutional learning and public trust. The group proposes a graduated transparency model with anonymized statistics, thematic reporting, and clearer public visibility into how ICANN considers and acts on recommendations.

Fourth, clarity of scope and authority: the draft does not clearly explain how the Ombuds role interacts with other accountability mechanisms, such as Reconsideration Requests and the Independent Review Process. NCSG recommends clearer guidance on boundaries, as well as a more explicit distinction between