Dear Michael and Alan,
Thanks for being the penholders to this.
I have some input to your proposed responses the questions asked.
Q: Disparity – there are clearly diverging best practices
regarding registration data accuracy for entities providing
domain name services in gTLDs and ccTLDs.
In my view, “mixing” ccTLDs and gTLDs here is not a good idea. The NIS2 will (very soon) color the Registrar business (for most registrars), but RrSG will easily reply that the ccTLD cannot be
compared with the gTLDs. In my view- a better question to ask RrSG is “How can you improve the required registrant verification for a gTLD registration?
The word “Improve” is of importance since the Registrars are obliged to verify the registration data in the RAA and RRA(s).
Sidenote: I will assume European based registrars will use the same verification techniques for a gTLD registration with a European registrant as required in NIS2 (whenever this is set).
Best
Steinar Grøtterød