Gee Caitlin - the language you have identified from the IRT deliberations doesn't appear to support the concept of a "drafting error".  I pasted some language below.  Can we please get a note from Dennis Chang of ICANN confirming the IRT determination that billing contact should be removed?  

Many thanks for tracking this down.
Anne

Note from Dennis as per link: "You will note that some have asked about the inclusion of Billing Contact fields in the Registrar Data Escrow Specification. We cannot remove it as a requirement for the following reasons: Current requirements pertaining to data escrow are specified in Section 3.6 of the RAA. Under these requirements, registrars must escrow the data described in Subsections 3.4.1.2 through 3.4.1.5, which includes but is not limited to the Billing Contact data.
Further, the Registration Data Policy includes requirements related to processing “Registration Data” as defined by the policy under Section 6. The Registration Data Policy will not modify or replace existing requirements under the RAA that are not specifically addressed and modified by the policy recommendations, including those requirements related to the processing of the Billing Contact data."




Anne Aikman-Scalese
GNSO Councilor
NomCom Non-Voting 2022-2026
anneicanngnso@gmail.com


On Thu, Mar 20, 2025 at 11:20 AM Caitlin Tubergen <caitlin.tubergen@icann.org> wrote:

Hi Anne,

 

Please find links to some of the IRT discussions on billing contact:

1. https://lists.icann.org/hyperkitty/list/irt.regdatapolicy@icann.org/thread/SJHU6MGP3FZL7DNFNCVS47Z2FDFXLOFC/.
2. https://lists.icann.org/hyperkitty/list/irt.regdatapolicy@icann.org/thread/UVWYHR4EG5BHRPG7HOE7ZHXI7KML45LV/


Kind regards,

 

Caitlin

 

From: Anne ICANN <anneicanngnso@gmail.com>
Date: Thursday, March 20, 2025 at 12:58 PM
To: Caitlin Tubergen <caitlin.tubergen@icann.org>
Cc: farzaneh badii <farzaneh.badii@gmail.com>, GNSO Council List <council@gnso.icann.org>
Subject: [Ext] Re: [council] Re: Preliminary research on EPDP discussion on billing contact

 

HI Caitlin - many thanks for this info.  Could you please forward the email showing the IRT's determination with respect to the billing contact drafting error?    Based on Thomas' explanation, I think it may be preferable for Council to refer to this as an underlying assumption of the outcome of the deliberations rather than a "drafting error". 

 

Thank you,

Anne

 

Anne Aikman-Scalese

GNSO Councilor

NomCom Non-Voting 2022-2026

 

 

On Mon, Mar 10, 2025 at 12:15 PM Caitlin Tubergen <caitlin.tubergen@icann.org> wrote:

Hi Anne,

 

Yes, you are correct – the billing contact discussion is directly linked to the Registration Data Policy. The Registration Data Policy was published in February 2024 and goes into effect on 21 August 2025.

 

Following the publication of the Registration Data Policy, as Contracted Parties began updating their systems, a question arose about billing contact (specifically the collection and transfer of billing contact info to the registrar data escrow agent).

 

I hope that answers your question, but please let me know if you have any additional questions.

 

Kind regards,

 

Caitlin

 

From: Anne ICANN via council <council@icann.org>
Reply-To: Anne ICANN <anneicanngnso@gmail.com>
Date: Monday, March 10, 2025 at 10:40 AM
To: farzaneh badii <farzaneh.badii@gmail.com>
Cc: GNSO Council List <council@gnso.icann.org>
Subject: [council] Re: Preliminary research on EPDP discussion on billing contact

 

Thank you, Farzi.  Question for staff:  Is this policy for Registration Data relevant to the Billing Inquiry?   Item 4 in the document says the policy becomes effective August 21 of 2025.

 

 

Anne

 

Anne Aikman-Scalese

GNSO Councilor

NomCom Non-Voting 2022-2026

 

 

On Mon, Mar 10, 2025 at 9:46 AM farzaneh badii via council <council@icann.org> wrote:

Hi all, 

 

Hope you are enjoying the opening ceremony. As promised I did some research on how and where billing contact was mentioned and discussed and so far have found the following:

 

 

Preliminary Research Background on Billing Contact at EPDP:

  1. August 2018 – Initial Mentions of Billing Contact:
    • Billing contact was first mentioned during EPDP calls.
    • Registrars discussed the utility of Admin/Tech contacts and their overlap with billing contacts.
    • A message from this period: Link [lists.icann.org] mentions the duplicity of contact roles (admin, tech, billing) and questions the necessity of collecting and sharing redundant information.
  1. November 2018 – EPDP Team Meeting #26:
    • A discussion on excluding billing contact, particularly in the context of ICANN’s involvement:
    • A message from this meeting: Link [lists.icann.org], which includes discussions on billing being related to a processing activity between contracted parties and their customers, with no involvement of ICANN.
  1. January 2019 – Discussion on Deletion of RDS Elements:
    • ICANN org sought input on deleting Administrative and Billing Contact information (note: billing contact data is not published).
    • Relevant email: Link [lists.icann.org]
    • Another email in 2019 from ICANN org asking the group to address billing contact: Link [lists.icann.org]
  1. Allan Woods’ Position (2019):
  1. Kristina Rosette (2019) – Discussion on Billing Contact and Registration Data:

6.     

    • Kristina Rosette argues that billing data should not be considered as part of registration data due to its vague connection with the domain registration process: Link [lists.icann.org]
    • She also mentions a proposed revision of the definition of “Registration Data” to exclude such data.
  1. Sarah Wylde (2019) – Support for Allan Woods’ Argument:
    • Sarah Wylde supports Allan Woods’ position and argues that billing is not a data collection purpose for ICANN: Link [lists.icann.org]
  1. Trang’s Query on Recommendation 11 and RAA:
    • Trang raised a question on whether the current text of Recommendation 11 would replace RAA Section 3.4 regarding billing contact: Link [lists.icann.org]
  1. Allan Greenberg response:
  1. Small Team B Discussion in 2019:
    • Billing contact was briefly discussed by Small Team B, noting that it is not considered within the scope of processing data for ICANN purposes: Link [lists.icann.org]

I hope this helps. 

 

 


Farzaneh 

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