Seb,

 

Below is a summary of the IPC Comments submitted on the Final Report on each of the 6 Recommendations.  Based upon these and the definitions from Section 3.6 of the GNSO Working Group Guidelines, I think the designation on Recommendation 1 needs to be changed from “Full Consensus” to “Consensus.”   Thank you for leading us through this process. 

 

Kind regards,

 

John

 

Recommendation 1: Continue the RDRS beyond the pilot period (keep the RDRS running voluntarily until a permanent solution or successor is in place). IPC does not support this recommendation. Rationale: The IPC believes the current RDRS pilot has fundamental shortcomings—such as very low registrar participation, inconsistent and opaque decision-making, and inadequate disclosure standards—that make it ineffective for legitimate data access needs. It fails to provide the predictable, fair access mechanism envisioned by the EPDP Phase 2 policy. Rather than extending an ineffective voluntary system, the IPC favors pursuing a system with mandatory participation (ideally involving both registries and registrars, but all registrars at a minimum), disclosure of underlying non-Privacy/Proxy data, obligatory “Thick WhoIs” data for registries consistent with the EU’s NIS-2 directive, and other measures that address concerns raised by the IPC on behalf of requestors.

 

Recommendation 2: Allow for authentication of interested requestor groups, beginning with law enforcement (introduce an accreditation system for certain users, starting with law enforcement). IPC supports this recommendation.  While the IPC does not support the continued operation of the RDRS in its current form, it supports this recommendation contingent upon the implementation of meaningful improvements to the system that include other interested requestor groups, including non-LEA consumer protection and brand

protection users, who should be included in the early work on authenticated access. The IPC views this recommendation as a constructive step toward addressing critical deficiencies identified during the pilot and aligning the system with broader policy goals and legal obligations.

 

Recommendation 3: Implement key system enhancements to sustain and evolve the RDRS post-pilot (including adding an API, improving the user interface, and optional participation for ccTLDs). IPC supports this recommendation. While the IPC does not support the continued operation of the RDRS in its current form, it supports this recommendation contingent upon the implementation of meaningful improvements to the system. The IPC views this recommendation as a constructive step toward addressing critical deficiencies identified during the pilot and aligning the system with broader policy goals and legal obligations.

 

Recommendation 4: Consider further policy work in specific areas – (4.1) Privacy/Proxy data (whether to require consideration of disclosure of P/P registrant data), and (4.2) inclusion of RDRS links in RDAP responses (to improve system discoverability). IPC supports this recommendation.  The IPC notes that such policy work will need to align with the EU’s NIS-2 directive.

 

Recommendation 5: Consider next steps on EPDP Phase 2/SSAD policy recommendations (reassess all 18 SSAD recommendations as a single package, and recommend the Board reject that package and send it back to the GNSO Council for further work). IPC supports this recommendation. However, the IPC’s support is contingent on the understanding that any new policy work will address the major flaws identified in the original SSAD model (e.g. lack of data accuracy requirements and the absence of differentiation between legal and natural persons) and will incorporate lessons learned from the RDRS pilot, as well as align with evolving legal obligations such as the EU’s NIS-2 directive.

 

Recommendation 6: Maintain the current RDRS Standing Committee with a narrowed scope (to advise on the continued operation, maintenance, and improvement of the RDRS while it remains in operation). IPC supports this recommendation

 

 

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