Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Submissions for this Proceeding

Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation

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Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - .au Domain Administration Limited
18 October 2025

Submission Summary:

auDA supports PDP processes to address DNS abuse mitigation, and offers suggestions in relation to the two topics identified for this PDP. We include information about how we deal with these matters in the .au ccTLD, which may be of value to the GNSO policy development process.


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Sommese, Raffaele
18 October 2025

Submission Summary:

With this comment we aim to highlight the need for additional transparency for effective DNS abuse mitigation. Based on our collaborative research on transient domains, we show that a measurable fraction of malicious domains evade current detection and reporting frameworks due to the lack of fine-grained and timely access to zone change information. We recommend that the forthcoming Policy Development Process explicitly address the visibility ...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Governmental Advisory Committee (GAC)
18 October 2025

Submission Summary:

The GAC supports the two issues identified for Policy Development Processes (PDPs) in the Preliminary Charter – Unrestricted Application Programming Interface (API) access for high-volume registrations and Associated Domain Checks – and recommends that chartering of the PDP(s) be constructed in such a way that it prioritizes concrete results before the next round of generic Top-level domains (gTLDs).

[...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - DNS AXE
18 October 2025

Submission Summary:

Support initiation of a PDP focused on (1) Unrestricted API access for high-volume registrations; (2) associated-domain checks; while (3) handling DGA/botnet coordination on a parallel, non-PDP track for speed and operational flexibility.


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Brickhouse, Mia
18 October 2025

Submission Summary:

 

Meta is grateful for the work done by the GNSO and the DNS Abuse Small Team to identify gaps within current policy. Meta hopes that with widespread support for these initiatives ICANN is able to swiftly address these gaps through the policy development process:


1. Advocate for Stronger Registrar Safeguards on Bulk Registrations and API Access - Support for a separate, narrowly scoped PDP<...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - ICANN Business Constituency (BC)
17 October 2025

Submission Summary:

DNS abuse is escalating faster than ICANN’s current policy development processes can address. Despite prior assurances of swift, focused efforts, timelines have stretched far beyond what the threat environment demands. The Business Constituency (BC) urges ICANN to implement a more agile and enforceable approach—by accelerating contractual updates with registries and registrars, establishing a standing advisory body for ongoing oversight, condu...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - INTA
17 October 2025

Submission Summary:

INTA thanks ICANN staff for preparing the issues report. We support further work on developing policies for mitigation of DNS Abuse across the information stack including at the Registrar and Registry level. Key issues to consider are: mitigation efforts at the Registrar level, requiring more transparency during the ICANN Compliance Process in terms of when complaints are deemed are "non actionable," and ongoing review of what methods of attac...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - NetBeacon Institute
17 October 2025

Submission Summary:

Comments from the NetBeacon Institute are supportive of the Preliminary Issues Report. The Institute suggests: a) That their be 2 PDPs instead of phases, b) that the associated domains check PDP be conducted first. The Institute also offers it's support to the PDPs as an expert contributor, if it's welcome.


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Public Interest Registry (PIR)
17 October 2025

Submission Summary:

Public Interest Registry (PIR) appreciates the opportunity to provide comments on the Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation and welcomes the detailed and thorough Preliminary Issues Report that has been produced by ICANN staff. We believe that policy development on DNS Abuse is an important step forward for the ICANN Community and we look forward to doing all we can to support it.


We...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Ethereum Name Service (ENS) Labs
17 October 2025

Submission Summary:

The Ethereum Name Service (ENS) Labs’ public comment supports ICANN’s proposal to initiate a Policy Development Process (PDP) on DNS Abuse Mitigation, urging a more proactive and coordinated approach to combat DNS abuse. Drawing from its experience monitoring digital‑asset–focused impersonation and phishing campaigns—including a recent study of over 2,200 malicious domains—ENS highlights the limits of current reactive tools like the UDRP and c...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Intellectual Property Constituency
17 October 2025

Submission Summary:

The IPC strongly supports additional improvements to the mitigation policies and contract requirements related to DNS Abuse, whether through the initiation of a GNSO Policy Development Process (PDP) focused on DNS abuse or through additional bi-lateral contract negotiations, whichever is quicker. The IPC believes that additional gaps highlighted in the PIR should be addressed concurrently or in parallel, rather than postponed for years. Rather...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Namecheap, Inc.
17 October 2025

Submission Summary:

Namecheap supports the creation of three sequential micro-PDPs for the API access, associated domain checks, and DGA-based abuse. The PDPs should remain narrowly scoped and run sequentially to maximize ICANN Community participation.

Namecheap supports the comments submitted by the CPH and the RrSG, particularly with regards to ensuring adequate and representative registrar participation.

Additional feedback is in the full comment...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Tucows
17 October 2025

Submission Summary:

Tucows appreciates the opportunity to comment and thanks ICANN Org for drafting.

In order to successfully address concrete issues by creating Policy that will solve real problems, the Charter must be split up into three Charters for three separate, sequential “micro”-PDPs.

The representative model works only when it is truly representative; as such the Charter should be updated to ensure even numbers across...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Policy staff in support of the At-Large Community, At-Large Advisory Committee (ALAC)
17 October 2025

Submission Summary:

Please find attached (PDF) the ALAC Statement on the Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation. Ratification information is included on the cover page.Kind Regards,

ICANN Policy Staff in support of the At-Large Community


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Registrar Stakeholder Group (RrSG)
17 October 2025

Submission Summary:

The RrSG supports the three topics identified in the Issue Report moving forward each as a separate PDP with its own Charter, and the work proceeding sequentially. Working Group representation should either be balanced and equitable across groups or follow the open membership model. The RrSG supports the consideration in the Report of a balance between preventative measures towards security and the need for an o...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Identity Digital Inc.
17 October 2025

Submission Summary:

Identity Digital Inc. supports the GNSO Council moving swiftly to initiate a PDP related to DNS Abuse, but encourages three issues identified by the Preliminary Report to be addressed through distinct, narrowly targeted PDPs.


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - (RySG), Registries Stakeholder Group
17 October 2025

Submission Summary:

The Registries Stakeholder Group (RySG) agrees with the three topics identified for additional community work. The RySG supports the Issue Report’s suggestion of launching PDPs on both Unrestricted API Access as well as Associated Domain Checks and the objectives of such PDPs. However, the RySG does not believe they should be combined into one PDP or as “phases” of one PDP. The RySG further ad...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Ministry of Electronics and IT, Government of India
17 October 2025

Submission Summary:

India supports ICANN’s effort to mitigate DNS abuse and endorses launching a single, narrowly scoped PDP to address two priority gaps, P1 (unrestricted API access) and C2 (associated domain checks), which enable large-scale malicious registrations. India recommends contractual vetting of high-volume API users, rate limits, and mandatory associated-domain investigations to curb bulk abuse.

India further proposes instant OTP-based email an...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Contracted Party House DNS Abuse WG
16 October 2025

Submission Summary:

The Contracted Parties House (CPH) DNS Abuse working group welcomes the opportunity to provide comments on the Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation.

Our working group members possess technical and operational expertise on the three subjects proposed for policy discussion. We support the initiation of distinct PDPs to discuss potential policy recommendations to the identified issues and look for...


Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation Submission - Piasecki, Maciek
15 October 2025

Submission Summary:

The comment explores potential for abuse of the proposed measures by governments against individuals and organisations, including vulnerable group, resulting in reduction of trust in the DNS systems. It explores what measures need to be taken by ICANN in order to actually follow on the commitment to follow applicable local laws (as expressed in the ICANN Bylaws), rather than simply rely on law enforcement requests. A three-tiered decision maki...