Public Comment

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Inter-Registrar Transfer Policy (IRTP) Part C Policy Development Process (PDP) Recommendations for Board Consideration

Comment/Reply Periods (*) Important Information Links
Comment Open: 22 October 2012
Comment Close: 12 November 2012
Close Time (UTC): 23:59 Public Comment Announcement
Reply Open: Cancelled – No Substantive Comments To Submit Your Comments (Forum Closed)
Reply Close:   View Comments Submitted
Close Time (UTC):   Report of Public Comments
Brief Overview
Originating Organization: ICANN Policy Staff
Categories/Tags: Policy Processes; Contracted Party Agreements
Purpose (Brief): Obtain community input on the Inter-Registrar Transfer Policy Part C recommendations adopted by the GNSO Council prior to ICANN Board consideration.
Current Status: The IRTP Part C Policy Development Process Working Group delivered its Final Report [PDF, 1.93 MB] to the GNSO Council on 9 October 2012. As required by the ICANN Bylaws, public notice is hereby provided of the policies that are considered for adoption as well as an opportunity to comment on the adoption of the proposed policies, prior to consideration by the ICANN Board of these recommendations.
Next Steps: ICANN Staff will prepare a summary of the public comments received that will be submitted to the Board in conjunction with the IRTP Part C recommendations adopted by the GNSO Council
Staff Contact: Marika Konings Email:
Detailed Information
Section I: Description, Explanation, and Purpose

The Generic Names Supporting Organization (GNSO) unanimously approved at its meeting on 17 October the recommendations of the IRTP Part C PDP Working Group. The recommendations, which are pending for Board action, propose:

  • Recommendation #1 – The adoption of change of registrant consensus policy, which outlines the rules and requirements for a change of registrant of a domain name registration. Such a policy should follow the requirements and steps as outlined hereunder in the section 'proposed change of registrant process for gTLDs'. (Note: further details concerning the rules and requirements for the change of registrant policy are detailed in the IRTP Part C Final Report [PDF, 1.93 MB] under the heading 'Proposed "Change of Registrant"Process for gTLDs' on page 4-8).
  • Recommendation #2: Forms of Authorization (FOAs), once obtained by a registrar, should be valid for no longer than 60 days. Following expiration of the FOA, the registrar must re-authorize (via new FOA) the transfer request. Registrars should be permitted to allow registrants to opt-into an automatic renewal of FOAs, if desired. In addition to the 60-day maximum validity restriction, FOAs should expire if there is a change of registrant, or if the domain name expires, or if the transfer is executed, or if there is a dispute filed for the domain name. In order to preserve the integrity of the FOA, there cannot be any opt-in or opt-out provisions for these reasons for expiration of the FOA. As recommended and approved as a result of the IRTP Part B PDP, Losing Registrars under IRTP-B are now required to send an FOA to a Prior Registrant. It is advised that Losing Registrars have the option to send a modified version of this FOA to a Prior Registrant in the event that the transfer is automated where the FOA would be advisory in nature.
  • Recommendation #3: All gTLD Registry Operators be required to publish the Registrar of Record's IANA ID in the TLD's WHOIS. Existing gTLD Registry operators that currently use proprietary IDs can continue to do so, but they must also publish the Registrar of Record's IANA ID. This recommendation should not prevent the use of proprietary IDs by gTLD Registry Operators for other purposes, as long as the Registrar of Record's IANA ID is also published in the TLD's Whois.

You are invited to submit your comments before final consideration of these recommendations by the ICANN Board.

Section II: Background

The IRTP is a GNSO consensus policy that was adopted in 2004 with the objective to provide registrants with a transparent and predictable way to transfer domain name registrations between registrars. As part of its implementation, it was decided to carry out a review of the policy in order to determine whether it was working as intended or whether there are any areas that would benefit from further clarification or improvement. As a result of this review, a number of issues were identified that were grouped together in five different policy development processes or PDPs, titled A to E, that are being addressed in a consecutive order. The IRTP Part C PDP Working Group was tasked to consider the following three questions:

  1. "Change of Control" function, including an investigation of how this function is currently achieved, if there are any applicable models in the country-code name space that can be used as a best practice for the gTLD space, and any associated security concerns. It should also include a review of locking procedures, as described in Reasons for Denial #8 and #9, with an aim to balance legitimate transfer activity and security.
  2. Whether provisions on time-limiting the Form Of Authorization (FOA) should be implemented to avoid fraudulent transfers out. For example, if a Gaining Registrar sends and receives an FOA back from a transfer contact, but the name is locked, the registrar may hold the FOA pending adjustment to the domain name status, during which time the registrant or other registration information may have changed.
  3. Whether the process could be streamlined by a requirement that registries use IANA IDs for registrars rather than proprietary IDs.
Section III: Document and Resource Links

IRTP Part C Final Report [PDF, 1.93 MB]
Inter-Registrar Transfer Policy (IRTP)

Section IV: Additional Information

(*) Comments submitted after the posted Close Date/Time are not guaranteed to be considered in any final summary, analysis, reporting, or decision-making that takes place once this period lapses.