Dear Colleagues, see below my report!
Best,
Matthias
 
 
Publications:
 
SAC129: SSAC Comments on GNSO Domain Name Registration Data Accuracy Concept Proposal
The SSAC appreciates the opportunity to provide input on the GNSO's efforts regarding domain name registration data accuracy. Although our response comes later than intended, we are grateful for your consideration.
 
Impact of Inaccurate Data:
  • Usability: Hinders effective communication and identification.
  • Security: Impairs law enforcement, anti-abuse efforts, and timely cybersecurity notifications.
  • Operations: Disrupts domain transfers, dispute resolution, and security analysis due to incorrect metadata (e.g., create/update dates, registrar info).
The SSAC consistently stresses the critical role of accurate data in enabling legitimate communications and mitigating abuse.
 
What Inaccurate Data Does Not Prevent:
  • It does not stop bad actors from continuing abusive domain use.
  • Harm prevention is still possible using other tools, but accurate data improves effectiveness. 
Vulnerable Stakeholders:
  • Law enforcement, cybersecurity firms, reputation service providers, researchers, brand protection teams, and operators of critical infrastructure (OS vendors, CAs, web/email/social platforms).
  • These groups rely heavily on registration data for investigations and system protections.
Problem Statement Recommendations:
  • Current Challenge: Lack of clear definitions, measurable standards, and inconsistent accuracy.
  • Consequences: Weakened DNS security, delayed investigations, and ineffective abuse mitigation.
  • Objective: Improve data accuracy to strengthen trust and security.
  • Proposal:
    • Define "accuracy" clearly.
    • Justify accuracy efforts through measurable benefits.
    • Address the potential commercial impacts.
    • Evaluate the implications of the EU's NIS2 directive on ICANN policies.
SSAC does not offer a formal problem statement but urges the GNSO to tackle key foundational issues including definitions, compliance mechanisms, and external regulatory impacts.
 
Administrative Notes:
  • The document reflects the consensus of the SSAC, with full transparency on contributors, disclosures, and any recusals.
 
SAC128: SSAC Comments on Draft Governance Document for the Recognition, Maintenance, and Derecognition of RIRs
1. General Support
  • SSAC supports the document’s goal to clarify RIR recognition, obligations, and derecognition procedures.
  • The document is a significant improvement over the current ICP-2 policy.
2. General Comments
  • Inconsistent Detail Levels: The document alternates between high-level principles and detailed operational guidance, which may cause ambiguity.
  • Recommendation: Clearly separate high-level principles from operational details, and consider placing implementation specifics in supplementary documents.
3. Specific Article Comments
Article 2.3(b)(i) – Derecognition Proposal Process
  • Concern: 25% threshold for submitting derecognition proposals could be exploited for disruptive or repetitive submissions.
  • Recommendation: Introduce safeguards such as cooldown periods and preliminary assessments.
Article 4.1(l) – Continuity Requirements
  • Concern: Vague terms like “sufficient” may allow non-functional data sharing formats.
  • Recommendation: Define clearer standards for continuity and data sharing expectations.
Article 5.3(a) – Transfer of Services Post-Derecognition
  • Concern: Requiring a smooth transfer from a derecognized RIR may be unrealistic in contentious situations.
  • Recommendation: Incorporate support structures similar to ICANN’s EBERO model to ensure continuity and data escrow during transitions.
4. Transparency
  • The document includes disclosures of interest, acknowledgements, and identifies any member withdrawals, ensuring transparency and consensus within SSAC.
 
SSAC127: DNS Blocking Revisited
What Is DNS and DNS Blocking?
  • The Domain Name System (DNS) translates human-readable domain names (e.g., example.com) into IP addresses that computers use to communicate.
  • DNS blocking is a technique to restrict access to online content by interfering with DNS queries. This can involve:
    • Pretending a domain doesn't exist.
    • Providing false IP addresses.
Why DNS Blocking Is Used
  • Often implemented because it's technically simple and low-cost.
  • Commonly used by governments and organizations for:
    • Public safety (e.g., blocking illegal content).
    • Censorship or regulation of online resources.
How DNS Blocking Works
  • By altering the behaviour of recursive resolvers (DNS servers that respond to user queries).
  • DNS blocking modifies the translation of a domain name into an IP address, effectively preventing access via DNS.
Effectiveness and Limitations
  • Blocking only works if users rely on the DNS infrastructure where the block is applied.
  • It can be bypassed through:
    • Alternative DNS resolvers.
    • VPNs or other routing methods.
  • Important: DNS blocking does not remove the content—only access through DNS is affected.
 Potential Side Effects
  • Collateral damage: Can impact unrelated services or domains.
  • Cross-border effects: May unintentionally affect users outside the blocking jurisdiction.
  • User confusion: May appear as a technical error, leading to risky behavior.
  • Legal ambiguity: Laws vary; determining whether DNS blocking is lawful or constitutes censorship depends on local context.
SSAC Recommendations

Recommendation 1: Any entity implementing DNS blocking should fully understand its technical and policy implications.

Recommendation 2: Entities implementing DNS blocking (governments, ISPs, organizations) should follow these principles:
  • Clear Objectives: Ensure DNS blocking aligns with intended goals.
  • Defined Policy: Maintain transparent, reviewed processes for deciding what to block.
  • Minimize Damage: Use methods that avoid overblocking or harming unrelated users.
  • Respect Boundaries: Do not affect users or networks outside your administrative control.

Recommendation 3: Recursive DNS server operators should use Extended DNS Error (EDE) codes to inform users when DNS blocking is active and aid troubleshooting.

This report updates previous SSAC advisories (SAC050 and SAC056 from 2011–2012) to reflect changes in technology and growing use cases for DNS blocking.
 
Final reviews:
SSAC's comment on the New gTLD Applicant Guidebook (AGB) has closed and the document is finalized as SAC130
  • It will be published this week.
Ongoing work parties:
  • DNSSEC Operational Considerations Work Party
  • Open-Source Software Work Party
  • Responsible Integration of External Technologies into the DNS
SSAC Membership Applications:
The application deadline is closed now and potential candidates are being assessed by the Membership Selection Committee.
 
SSAC Workshop:
Will be held in September in Mexico City.