Marco I like Scott's idea and also (wearing my CPH Techops co-chair hat) there is an open call for topics for the Ry/Rr (CPH) techops to discuss during ICANN 76 in March that some or all of these might be good to raise.

There are some topics that will suddenly be very important as NIS2 considerations which should receive some attention - I think you are starting the right conversation, it just needs a home.

Typically we're less policy and more addressing details of technical or operational implementation of policy outcomes, but there are situations such as the 2018 tempspec that help our industry navigate consequences of regulation made with low sophistication about our industry and how it actually works or where they might but have little concern for it are taken by regulators.

-Jothan

On Tue, Jan 31, 2023 at 8:28 AM Hollenbeck, Scott via gtld-tech <gtld-tech@icann.org> wrote:

With respect to the IETF, the regext working group is the place to bring up the topic:

 

https://datatracker.ietf.org/wg/regext/about/

 

Scott

 

From: gtld-tech <gtld-tech-bounces@icann.org> On Behalf Of Michele Neylon - Blacknight via gtld-tech
Sent: Tuesday, January 31, 2023 11:22 AM
To: InterNetX - Marco Schrieck <marco.schrieck@internetx.com>
Cc: gtld-tech@icann.org
Subject: [EXTERNAL] Re: [gtld-tech] NIS2 and impact on EPP

 

Caution: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 

Marco

 

The requirements will be national not per registry

 

So as an Irish company we’ll be obliged to follow one set of rules and InterNetX will have to follow a different set.

 

Bear in mind most of the registries aren’t European, so I’m not even sure how they’re going to be viewing this

 

Related to this:

 

https://digital-strategy.ec.europa.eu/en/funding/call-tender-study-domain-name-registration-data

 

So I strongly suspect the EU has no idea what anyone is doing or is likely to do.

 

I’d also prefer that if there’s going to be any discussions around EPP changes / tweaks for this that they be pushed more towards IETF as this is going to have as much impact on ccTLDs (in fact more) than it will on gTLDs.

 

Regards

 

Michele

 

 

--

Mr Michele Neylon

Blacknight Solutions

Hosting, Colocation & Domains

https://www.blacknight.com/

https://blacknight.blog/

Intl. +353 (0) 59  9183072

Direct Dial: +353 (0)59 9183090

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Some thoughts: https://ceo.hosting/

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From: InterNetX - Marco Schrieck <marco.schrieck@internetx.com>
Date: Tuesday, 31 January 2023 at 16:18
To: Michele Neylon - Blacknight <michele@blacknight.com>
Cc: gtld-tech@icann.org <gtld-tech@icann.org>
Subject: Re: [gtld-tech] NIS2 and impact on EPP

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Hello Michele,
I can't agree with you completely. Because it would be good to have some discussions in the community beforehand.
 
My fears are that now many registries are thinking about their processes and it would be good to work together here and create some guidelines.
 
From my point of view, we will probably have to deal with several models. 
 
There will probably be registry validated or registrar validated models, with all their different forms.
 
 
Of course the legislation will not be the same everywhere and there will be different requirements per registry.
 
But it would be useful if registries and registrars agree on a set of rules.
 
Some that come to my mind ad hoc 
- Visibility in public services (WHOIS/RDAP)
- Billing process:
  - Directly billed and then on HOLD until verification.
  - Billing only after successful verification
- Handling of documents, if any are needed only the validator should request them.
- Handling of registrant changes and transfers.
 
 
Regards
Marco

Am 30.01.23 um 23:33 schrieb Michele Neylon - Blacknight:

I’d like to see the actual national legislation before jumping to assumptions
 
Also as it’s not going to be 100% uniform legislation and there could easily be differences between member states I can see it being quite complex 
 
 
 
Mr Michele Neylon
Blacknight Hosting & Domains
https://www.blacknight.com
@mneylon 
Sent from mobile so typos and brevity are normal 
 
On 30 Jan 2023, at 22:24, InterNetX - Marco Schrieck via gtld-tech <gtld-tech@icann.org> wrote:
 
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Hi all,
 
I wanted to ask if anyone has thought about the impact of NIS2 on EPP,
Especially  the validation of domain holder?
 
There are many issues here regarding protocol and processes.
 
E.g.
How are certain checks of owner data represented in EPP/RDAP/Whois.
 
Maybe we can work out some kind of best practice for the registries and
registrars here.
 
What is your opinion ?
 
Regards
 
 
Marco Schrieck
 
Director Development
 
Marco Schrieck
Bereichsleiter Entwicklung
 
--
InterNetX GmbH
Johanna-Dachs-Str. 55 • 93055 Regensburg • Germany
Tel. +49 941 59559-0
 
internetx.com - internetx.com/linkedin - internetx.com/twitter
 
Geschäftsführer:
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Marco Schrieck
Bereichsleiter Entwicklung
 
-- 
InterNetX GmbH
Johanna-Dachs-Str. 55 • 93055 Regensburg • Germany
Tel. +49 941 59559-0
 
internetx.com - internetx.com/linkedin - internetx.com/twitter
 
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