Dear colleagues, I apologize for the delay in taking on my action item from our call last week. Please see the draft below for input/discussion. Kind regards, Justine *Questions to ICANN Contractual Compliance* Given the 2024 amendments to the Registry Agreement (RA) and Registrar Accreditation Agreement (RAA) regarding DNS Abuse mitigation obligations have been in effect for over a year (i.e. since 5 April 2024), the GNSO Council Small Team on DNS Abuse would like to know as follows:- 1. Is ICANN Contractual Compliance able to articulate whether the said amendments have been effective in facilitating clearance of complaints received by ICANN since 5 April 2024? In particular, can examples be provided to demonstrate how the amendments have enabled ICANN Contractual Compliance to take action against any non-complying registry and/or registrar, which action ICANN Contractual Compliance was unable to take prior to the amendments coming into effect? 2. What steps is ICANN Contractual Compliance taking to examine and report on remaining gaps in its monitoring and measuring the performance of registries and registrars against their DNS Abuse mitigation obligations since the amendments came into effect? 3. What additional tools might ICANN Contractual Compliance need to (further) improve its ability to enforce the RA or RAA in the event non-compliance is identified? On Sat, 24 May 2025 at 00:49, John Emery via gnso-dnsabuse-smallteam < gnso-dnsabuse-smallteam@icann.org> wrote:
Dear DNS Abuse Small Team,
Please find attached the action items and meeting notes from the 22 May 2025 DNS Abuse Small Team meeting. The slides are available to download through this link <https://icann-community.atlassian.net/wiki/download/attachments/178389129/sl...> and can also be found on the Small Team wiki space: https://icann-community.atlassian.net/wiki/x/iQCiCg
*Action Items*
*Item*
*Responsible*
*Description*
Draft question to compliance on amendment effectiveness
Justine Chew
Share draft with Small Team for input.
Review NetBeacon white paper
All members
Consult with stakeholder groups.
Set up potential presentation from NetBeacon
Staff
Optional follow-up action.
Provide summary of identified “issues/gaps” in reviewed reports
Staff
Add to the next agenda Share draft with a small team for input.
Continue review of timeline of Small Team delivery plan
Small Team
Aim to make suggestions earlier than the initial 6 months as data review suggests an “issue report” might be prudent.
*Agenda*
*1. **Welcome*
*2. **ICANN DNS Abuse Mitigation Requirements Overview*
- ICANN Org presented <https://docs.google.com/presentation/d/1XFBkeQi4xgHiP1Ssa4P_zKNYXtC9-KrE/edi...> a high level overview of ICANN DNS Abuse Contract Requirements. The webinar link can be found here. <https://www.icann.org/en/engagement-calendar/details/icann-webinar-series-fo...> - *Enforcement and Monitoring Enhancements:*
- Contractual compliance audit program—two audits/year, 6 months each.
- Support from KPMG for evaluation.
- Monitoring includes media reports, complaints, and behavioral patterns.
- Plans to integrate KPIs for transparency and daily operations.
- *Discussion Highlights:*
- Small Team members noted that the DNS Abuse landscape is broader than what is being reported to ICANN.
- Stressed the need for evidence over assumptions; some abuse is mitigated before reaching ICANN, which reflects functioning registrar systems.
- Members noted the need to understand whether compliance believes the new tools are effective.
- Recommended formally asking ICANN compliance whether contractual amendments are working.
*Action Item: *Justine Chew to draft a question to ICANN Compliance asking whether contractual amendments have enabled improved mitigation actions and if so, how. This will be circulated among the Small Team for input and then forwarded via staff.
*3. **Discussion on INFERMAL Report*
- ICANN Org presented <https://docs.google.com/presentation/d/1XFBkeQi4xgHiP1Ssa4P_zKNYXtC9-KrE/edi...> a high level overview of INFERMAL study. The webinar link can be found here. <https://www.icann.org/en/announcements/details/icann-webinar-to-discuss-infe...>
- *Discussion Highlights:*
- Study is valuable but not holistic; cautioned against using findings to justify increasing domain prices, especially for vulnerable groups.
- Suggested rewording questions to focus on abuse trends, not entire “business models.”
- Supported focusing on specific business practices that may lead to abuse trends.
- Requested clarification on the definition of DNS abuse being used.
- Use ICANN’s contractual definition of DNS abuse, as reflected in contract amendments.
- Clarified that redefining DNS abuse is not the small team’s scope but could be identified as a gap for future council consideration.
*4. **Timeline and Project Plan Review*
- DNS Abuse mitigation gaps remain based on data reviewed. - Small Team to identify what gaps remain and which could be covered in an issue report. - Adjusted focus would lead to earlier delivery of assignment. - Small Team Timeline to be reviewed – Aim to provide suggestions to Council significantly earlier than the initial 6month deadline.
*5. **AOB*
- *Discussion Points:*
- NetBeacon paper <https://netbeacon.org/wp-content/uploads/2025/05/2025-05-NetBeacon-PDP-Whitepaper-Final.pdf>provides potential PDP topics.
- All reports discussed today are seen as one data source—not prescriptive or final recommendations. The aim is to identify remaining gaps that can be included in an issue report.
- Importance of cross-consultation with stakeholders emphasized.
- *Action Items:*
- Suggestion to invite NetBeacon to present to the Small Team for further clarification.
- Staff to support categorization or summary of report insights to guide the Small Team's review.
Thank you,
On behalf of the support staff of the DNS Abuse Small Team
––––––––––––––––––––
John R. Emery, Ph.D.
Policy Development Support Senior Specialist
Generic Names Supporting Organization (GNSO)
Internet Corporation for Assigned Names and Numbers (ICANN)
www.icann.org
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