2026-05-18
DNS Abuse Mitigation PDP1 WG
Action Items:
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Staff to update strawperson language on CQ5 and 6. Use the RrSg provided language as basis.
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For CQ7 Staff to use/consider all WG input from CollabDoc and
provide a cleaned up version for WG review categorizing the straw persons into Recommendations, Rationale and Implementation Guidance, where sensible and relevant.
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NCSG to provide further examples on potential adverse impact on legitimate registrants.
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WG members to review ICANN Advisory
(see guidance “prompt”) and determine if additional guidance is needed from compliance. If so, draft a question in CollabDoc.
(ICANN Compliance Advisory on DNS Abuse Contract Amendments:
https://www.icann.org/en/contracted-parties/advisories/documents/advisory-compliance-with-dns-abuse-obligations-in-the-registrar-accreditation-agreement-and-the-registry-agreement-05-02-2024-en)
Important docs/links:
High-Level notes:
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Welcome (5min)
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Discuss Strawperson CQ5 (30min)
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WG members emphasized that ADCs are intended to identify potentially domains registered for DNS Abuse and are distinct from mitigation actions themselves.
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The current PDP was characterized as focused on detection and identification activities rather than enforcement outcomes. WG members noted that mitigation
actions already fall under existing Registrar Accreditation Agreement (RAA) obligations and argued that remedies tied specifically to mitigation actions fall outside the scope of the present PDP.
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Others noted that in practice the distinction between investigation and mitigation may not always be clear from the perspective of registrants.
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WG members noted that ADC-related processes could potentially lead to account suspensions, takedowns, erroneous associations, or other adverse impacts even
before a formal enforcement determination is finalized.
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WG members noted that a PDP may identify issues outside its immediate charter and recommend that the GNSO Council address them through future policy work.
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WG members acknowledged that the question of recourse tied specifically to mitigation actions may require future policy work, while still recognizing the
need to evaluate whether ADC activities themselves create identifiable harms requiring safeguards.
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RrSG provided Strawperson text on CQ5 which will be included in the CollabDoc for WG review.
3.
Discuss Strawperson CQ6 (30min)
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WG discussed whether ADCs should be subject to fixed timelines or whether the existing RAA standard of acting “promptly” should remain the governing principle.
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WG members discussed proposals referencing timelines such as 72 hours versus more flexible standards tied to operational context and proportionality.
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Many WG members supported retaining the existing “prompt” standard already embedded in RAA Section 3.18.2.
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WG members noted the potential trade-off between fast action and conducting sufficiently complete and defensible ADC investigations, particularly for sophisticated abuse campaigns requiring deeper
analysis.
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WG members noted that “prompt” has historically been sufficient across ICANN contractual frameworks and questioned why ADCs should be treated differently and also noted that the term “promptly” already
appears multiple times throughout the RAA and has not previously been considered unenforceable.
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Some WG members suggested language such as “prompt but no later than 72 hours”.
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RrSG provided strawperson on CQ6 which will be included in the CollabDoc.
4.
Start deliberations on CQ7 (20min)
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Discussed that Policy Recommendation should not be prescriptive.
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WG discussed that by discussing and answering CQ1-6 they have already provided answers to this question.
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Chair noted that current language can be categorized into Policy Recommendations, Rationale and Implementation Guidance
(where relevant) for WG review and further discussion.
5.
AOB (5min)
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Chair to provide an update to WG on Impact Assessment approach and next step.