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

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:
Thomas Mörz (CEO), Hakan Ali, Elias Rendón Benger
Amtsgericht Regensburg, HRB 7142

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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

Geschäftsführer:
Elias Rendón Benger (CEO), Lars Krämer
Amtsgericht Regensburg, HRB 7142