Thank you for your thoughts, Tapani and Claude. They help me shape my own view on the matter.
I have also been thinking a lot about this subject since Mumbai. I have come to frame the question as follows: "should same-entity treatment at the second level be our default policy in order to improve user safety, despite the additional operational burden it creates?"
I am leaning toward the view that our case is somewhat different from ordinary second-level diacritic handling. If at the top level these TLDs are being treated as a coordinated set, there is a real policy argument that the related second-level space should also be coordinated enough to preserve predictability.
I've come to think that the strongest argument for a same-entity approach comes from a market perspective, in that this would actually promote a less predatory model, since we would not be pushing registrants into buying defensive bundles of domain names. The strings would depend on each other as a matter of policy, not of whether you registered the N permutations of Latin Diacritics contained there. If you own "café.sãopaulo", the corresponding "cafe.sãopaulo/saopaulo" forms should not simply be available for a different party to register because you did not defensively buy every version. The registrant should pay for what they actually want to use, without creating a separate market for defensive registrations. It's sustainable market formation via policy.
That said, the operational burden is real. Same-entity at both levels would affect registry systems, registrar behavior, availability checks, lifecycle operations, transfers, dispute outcomes, and possibly existing registrations. It's way messier than the alternative, and creates all sorts of issues that Tapani highlighted. Does this discourage gTLD applicants from thinking that supporting LDs is a viable business? Or are the applicants so niche anyway that they will understand the limitations? I don't know.
As usual, my views shouldn't determine any position. This is just where I have arrived so far.
Best,
Dear Tapani,
In Canada both .ca and .quebec are enforcing the same entity principle at the second level. There are some minor difference in the policy between .ca and .quebec, but essentially the result is the same.
Here is the .ca (CIRA) policy :
How does .CA manage IDNs?
In 2012, CIRA introduced support for the full range of French characters in .CA domain names: é, ë, ê, è, â, à, æ, ô, œ, ù, û, ü, ç, î, ï, ÿ. When a .CA is registered, all variations of a domain name with these accented characters (what we call the “administrative bundle”) are reserved for the registrant and cannot be registered by anyone else.
Although these domain names are reserved for the registrant, they are not active – that is they do not automatically resolve. The registrant must register them with a registrar that offers this service. Each domain name you wish to use must be registered individually, with the same registrar. Each of these registered names will have its own lifecycle.
To use an example, there are 18 variants in the administrative bundle for www.cira.ca:
- www.cira.ca
- cirâ.ca
- cirà.ca
- cîra.ca
- cîrà.ca
- cïra.ca
- cïrâ.ca
- cïrà.ca
- çira.ca
- çirâ.ca
- çîra.ca
- çîrâ.ca
- çîrà.ca
- çïra.ca
- çïrâ.ca
- çïrà.ca
- çirà.ca
For .QUEBEC, when a registrant seeks a second level domain name with a diacritic (IDN), he will get it's ASCII fallback second level domain name at the same time. And over and above a same .CA bundle policy gets in place, enforcing the same entity policy.
I cannot speak for .ca or CIRA, but for .QUEBEC, when the .QUÉBEC will be delegated, the same entity bundgling policy will be extended at the second level for all, including for the already delegated .quebec. with or without diacritic.
This is very conservative, one could say, but it gives a security space for the Brand, the registrants and the users.
This was done, at the Registry level, and the Registry Operator level.
We understand that the registries want to keep an upper hand of what policy should be put in place in their own turf at the second level. We respect that, and we did not propose that the way it is manage here in Canada is a ones fits all. I remember during the IDN PDP 2, that this was discussed for variants and the decision regarding the restriction at the second level was left to the registry, and not a policy in the PDP.
I hopes it helps to understand that café.quebec, cafe.quebec, café.québec, cafe.quebec and all the others câfé, cäfé, càfé, cafe, cafê, cafè, cafë, càfë, etc etc would be all be part of one bundle, one registrant, one registrar, one Registry operator, : or the same entitySo no confusion here. Similarity yes but for the same entity.
Best
Claude
Le 22 mai 2026 à 2 h 32, Tapani Tarvainen via Gnso-latin-diacritics <gnso-latin-diacritics@icann.org> a écrit :
Thinking of the test.domain vs tést.domain scenario, I find myselfconcluding that enforcing the same entity principle on 2nd leveldomains is not viable.
Confusion potential is real, but as it already exists for extant TLDs,ASCII as well as IDN ones, and we cannot do anything about those, canor should we enforce stricter rules for our case?
Same entity requirement on 2nd level could also have some undesirableside-effects. What would happen if cafe.quebec and café.quebec werealready extant with different registrants when .québec is applied for?
Should that block .québec application? Or should the policy havesome kind of grandfather clause?
I don't see why café.quebec and cafe.quebec would be less likely tocause confusion than cafe.québec and café.québec. If anything thelatter should be safer simply because people using .québec are morelikely to pay attention to accents.
Likewise, sakki.fi, säkki.fi and šakki.fi (all extant domains withdifferent registrants) are unlikely to confuse Finnish speakers,and others are less likely to use .fi domains.
I guess we could require applicants to document their policy in thisregard, perhaps including that they must alert registrants to theissue, but I would not insist on strict same entity principle on 2ndlevel.
I remain, however, open to persuasion. :-)
--Tapani Tarvainen_______________________________________________Gnso-latin-diacritics mailing list -- gnso-latin-diacritics@icann.orgTo unsubscribe send an email to gnso-latin-diacritics-leave@icann.org
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