The Noncommercial Stakeholders Group (NCSG) acknowledges the importance of ICANN’s DNS Abuse mitigation efforts? and recognizes the Council's extensive discussions, public comments, and ongoing efforts in this area. However, the NCSG has significant concerns regarding the motions submitted to the Council list.
The NCSG acknowledges the motion's sequential framing; the practical effect remains two separate PDPs rather than a truly integrated phased workstream. We therefore do not support establishing two separate PDPs as proposed in the motion. Given the NCSG’s limited capacity to engage, having two PDPs at the same time is not feasible. Having one PDP completed in phases would ensure NCSG capacity throughout the overall process. While the motion indicates that PDP 1 will focus on Associated Domain Checks and PDP 2 on API functionality, the language stating that "the GNSO Council will revisit the draft Charter on DNS Abuse Mitigation PDP 2 when deemed appropriate based upon the progress and resources needed for PDP 1" does not clearly establish whether these constitute phased workstreams or truly separate PDPs. The NCSG would prefer a phased PDP approach rather than two concurrent or sequential independent processes for these related topics. Moreover, it seems that the final issue report still recommends concurrent PDPs despite our emphasis that they should not be concurrent which makes the process more ambiguous. This incongruity risks causing confusion and requires Council discussion to resolve them.
Additionally, NCSG believes the Council should first discuss which specific topics warrant prioritization based on the recommendations in the Final Issue Report, and then provide recommendations of approaches to the PDP regarding timelines and scope. We also believe the PDP participants should decide which topics they should prioritize and provide a rationale for it, with clear timelines.
NCSG's most significant concern remains the process itself. There has been insufficient deliberation regarding the charter structure and the working group model to be adopted during the PDP process. In our view, proceeding without this proper discussion risks a rushed process that could result in inadequate review and unsound policy outcomes. The motion presents a draft charter for the Associated Domain Check PDP and for API before the Council has thoroughly discussed and decided upon the representation and working group model to be adopted. And although it's not the first time a draft charter emerges from a final issues report, the GNSO council holds the role of managing PDPs and, therefore, the role of scoping said efforts. Adequate deliberation on these structural questions is essential to ensuring that the Working Group can function effectively and that NCSG can participate meaningfully, as well as a drafting team for finalizing the charter/charters.
To conclude, the NCSG does not oppose convening PDPs on the identified topics. However, we caution against prioritizing the Associated Domain Check initiative, as it raises significant concerns regarding registrant privacy and identification risks.
The NCSG would appreciate deferring a vote on this motion while ensuring the council thoroughly deliberates on the working group model and representation structure and how to move forward on convening the PDPs and drafting the charters and focusing on issues. ***
In a nutshell, the NCSG will defer a vote on this motion, and we would welcome if more time was allocated during our upcoming meeting to address these issues and the final issues report._______________________________________________Hi Damon.
Thank you, your second is noted.
The motions page will be updated shortly.
Kind regards,
Devan
From: "Ashcraft, Damon via council" <council@icann.org>
Reply-To: "Ashcraft, Damon" <dashcraft@swlaw.com>
Date: Friday, December 5, 2025 at 9:00 AM
To: "council@icann.org" <council@icann.org>
Subject: [council] Re: Friendly amendment to the Motion - DNS Abuse Mitigation - PDP 1 and PDP 2
All,
Please note that I am seconding this motion.
Thanks, Damon
J. Damon Ashcraft
, P.C.
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From: Terri Agnew via council <council@icann.org>
Sent: Thursday, December 4, 2025 12:08 PM
To: jen@dot.asia; council@icann.org
Subject: [council] Re: Friendly amendment to the Motion - DNS Abuse Mitigation - PDP 1 and PDP 2
[EXTERNAL] council@icann.org
Hi Jen,
The motion has been updated on the wiki page: https://icann-community.atlassian.net/wiki/x/ZKifBg [icann-community.atlassian.net]
GNSO Council, as a reminder this will need a second. Please email the mailing list to do so: council@icann.org
Thank you.
Kind regards,
Terri
Policy Team Supporting the GNSO
From: jen--- via council <council@icann.org>
Reply-To: "jen@dot.asia" <jen@dot.asia>
Date: Thursday, December 4, 2025 at 12:33 PM
To: "council@icann.org" <council@icann.org>
Subject: [council] Friendly amendment to the Motion - DNS Abuse Mitigation - PDP 1 and PDP 2
Thank you Feodora and staff team for making these corrections and also making sure the references in the Charters reflect the language used in the rest of the Final Issue Report.
In light of this, I am suggesting a friendly amendment to the motion I brought to Council to align with this updated corrected language:
https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111126628/Motions+2025-12-11 [icann-community.atlassian.net] (original motion)
Specifically in whereas clause 9:
- Informed by the DNS Abuse Small Team`s recommendations, the Public Comment on the Preliminary Issue Report, the ICANN84 DNS Abuse working sessions, and the clear preference for narrowly scoped Policy Development Processes (PDP), the Final Issue Report recommends separate PDPs on:
- Associated Domain Checks: A framework
A reactive approachrequiring registrars to proactively pivot to investigate domains linked to malicious actors, particularly in cases of high-volume domain registrations used for DNS Abuse campaigns; and,- Safeguards for Application Programming Interface (API) access to new customers: A proactive approach that seeks to introduce friction for new customer accounts, prior to gaining access to high volume registration tools until trust is established.
I’ve been advised by staff that procedurally I can also accept this amendment as friendly in this same email, and call for a second for the motion. Many thanks to all!
Best,
Jen
From: Feodora Hamza via council <council@icann.org>
Sent: Thursday, December 4, 2025 1:20 PM
To: council@icann.org
Subject: [council] Re: Final Issue Report on a PDP on DNS Abuse Mitigation
Dear Councilors,
please find below an updated version/link to the Final Issue Report on DNS Abuse Mitigation. Updates were made to the Annex A and B on the DNS Abuse Mitigation Charters, which included some minor typographical errors and the details of the Working Group representative structure that have been carried over from the Preliminary Issue Report and included in the Charters of Annex A and Annex B. The lack of inclusion of these was a formatting error and this was remedied.
Finally, the Charter language of the Associated Domain Checks was updated in Annex A on page 48 as follows: Associated Domain Checks: A framework
A reactive approachrequiring registrars to proactively pivot to investigate domains linked to malicious actors, particularly in cases of high-volume domain registrations used for DNS Abuse campaigns.
- Please utilize the updated link here: https://gnso.icann.org/sites/default/files/policy/2025/draft/issue-report-dns-abuse-mitigation-04dec25-en.pdf [gnso.icann.org]
Kind regards,
Feodora on behalf of the Support Team
From: Feodora Hamza via council <council@icann.org>
Reply to: Feodora Hamza <feodora.hamza@icann.org>
Date: Monday, 1 December 2025 at 21:02
To: "council@gnso.icann.org" <council@gnso.icann.org>
Subject: [council] Final Issue Report on a PDP on DNS Abuse Mitigation
Dear GNSO Council,
Please find below the link to the Final Issue Report on a PDP on DNS Abuse Mitigation – updated based on the Public Comment received.
The most notable change compared to the Preliminary Issue Report is the Annex containing two draft charters starting on page 46.
Final Issue Report: https://gnso.icann.org/sites/default/files/policy/2025/draft/issue-report-dns-abuse-mitigation-01dec25-en.pdf [gnso.icann.org]
Kind regards,
Feodora Hamza
Policy Development Support Manager (GNSO)
Internet Corporation for Assigned Names and Numbers (ICANN)
Mobile: +32 496 30 24 15Email: feodora.hamza@icann.org
Website: www.icann.org
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