I recommend making it clear there are three classes of proxy providers:

A proxy provider that is operated by an accredited registrar or a reseller of an accredited registrar. (I shouldn't have to mention resellers explicitly. In my lexicon, a reseller is an agent of the registrar and is bound by all of the terms in the registrar's contract, but others seem to feel resellers are somehow separate from registrars.)
A proxy provider that is not operated by an accredited registrar but is publicly known to be a proxy provider.
All others, including private arrangements, businesses that offer proxy services without public visibility, and incidental arrangements such as when the tech contact registers a domain name for its customer but puts its own name in the registrant field.

We include each of these cases in the diagram. Or create two or three diagrams. In any case, let's provide a policy that deals with all of these cases.

Regarding (1), the registrar constructively knows the full details about the registrant. Saying the registration is hidden behind a proxy is a bit misleading. A clearer and more direct interpretation is the registrant details will not be disclosed to a certain class of requests. Thus, the role of a known proxy provider is to mark the registrant data as requiring a higher level of privacy than it would otherwise receive.

Regarding (2), the registrar should treat the proxy provider as the legal registrant, and treat the proxy provider as neither a business (legal person) nor an individual (natural person), but as a third type of entity.

Regarding (3), there's nothing special to be done.

All of the above applies to proxy providers. Privacy providers are, in my opinion, a bit different. A privacy provider is doing two things. First, they are providing contact information for a distinctly different role, viz where to direct correspondence. Second, they are explicitly protecting the contact details of the registrant. In this regard, they are like a proxy provider in (1) above. That is, they are marking the registrant's contact details as sensitive and hence not to be disclosed to a certain class of requestors.

Thanks,

Steve

On Tue, Jan 27, 2026 at 8:55 AM Jessica Puccio via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:

Hello IRT -

This is a friendly reminder to please take some time to review the Draft Requirements Flow visual and share your comments ahead of our next discussion.

As you view the graphic, please note the goal is to provide a visual means to understand the course of requirements to ultimately produce a draft Consensus Policy.

Please have all feedback submitted directly on the graphic by EOD, Thursday, 29 January; only highlighting the specific area of related text when making comments. Instructions attached.

Thank you for your time and cooperation.

Best Regards,

--

Jessica Puccio

Sr Coordinator, Review Support and Accountability Projects

Internet Corporation for Assigned Names and Numbers (ICANN)

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