Subject: [EXTERNAL] [council] Follow up on potential referral to the SPIRT
From: Susan Payne via council <[email-masked]>
To: Anne ICANN via council <[email-masked]>
Date: Wed, 27 May 2026 16:44:49 +0000
List-Id: "The 24 members of the GNSO Council govern policy development in the GNSO." <council.icann.org>

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Dear Councillors

Following the AOB item regarding a potential issue for referral to the SPIRT presented by Sam Demetriou on last week’s Council call, Councillors are asked to seek the input from their SG and Cs now, so that we can be in a position to vote  on whether to refer this to the SPIRT during our June meeting, in order that the SPIRT can assess the issue and discuss it with Org. 

As a reminder, the issue is as follows:

In the draft version of the base registry agreement for the Next Round applicants there was a requirement that all registry operators would only use extensible provisioning protocol (EPP) extensions  that are registered with the Internet Assigned Numbers Authority (IANA). IANA maintains a register of EPP extensions, and there is a very specific process involving the IETF where proposed new EPP extensions can be approved for inclusion in this IANA register.  In certain cases, gTLD registries have historically used EPP extensions that are not included in that database, and so when reviewing the draft base RA requirements the RySG flagged this as a problem. As a result of this, ICANN agreed to remove the requirement  from the Next Round base RA. 

Despite the removal of this requirement from the base RA, there remain some requirements under the technical questions and the registry system testing that back-end registry service providers (RSPs)  have to go through that pertain to this requirement. So, there are some technical questions to evaluate RSPs that require the applicants to attest that they will only use the EPP extensions that are registered in the IANA registry. That requirement is also  tested during the registry system testing. There is therefore a misalignment between what's tested-for and what's required to be attested-to during registry system testing, and what's actually required under the registry agreement. 

The RySG has therefore brought this issue to Council, with a view to Council requesting that SPIRT and ICANN org consider how to address this misalignment, for example by making optional the attestation  that RSPs will not use EPP extensions that are not in the IANA registry.  This would require a revision to the Registry Service Provider Handbook that lists out the registry questions that have to be evaluated, as well as the registry system testing that tests  against this criteria. Potentially this would also need to apply to those RSPs that have already completed the testing, so that they should not be held to a standard that has been removed from the base RA.

Many thanks.

Susan Payne  
 Head of Legal Policy 
28 Little Russell Street,
London WC1A 2HN, UK
T +44 (0) 20 7421 8250
D +44 (0) 20 74218 255 
comlaude.com 
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