Catching up on the threads on this, I am happy to chime in on the email.
The arrangements to be put in place for compliance with the Registration Data Policy are complex. Registry operators shall need to ensure that we have adequate time to not only develop, but test and implement/launch system updates to address the expected changes. We also must ensure we engage in clear and collaborative efforts with registrar partners to minimize, to the greatest extent possible, the impact of implementation to them and their operations. It would be our sincere hope that implementation expectations would remain as per usual, i.e. that the contracted parties may implement the policy at any time post the publication of the final policy, but no later than the last date for implementation. This will ensure and support a coordinated, phased and frankly a more stable implementation, for the benefit of all parties and the broader DNS.
We also would like to remind that this path to implementation is required in the Interim Registration Data Policy. The current policy clearly notes that “During this stage, the contracted parties may implement either the Interim Policy or the Registration Data Policy in its entirety, or elements of both, as they prepare for the effective date of the Registration Data Policy document.” This was specifically inserted to provide flexibility to contracted parties, so as to ensure a measured and careful implementation period between publication of the policy and the final implementation date, acknowledging the likely complexity of this endeavor.
Warmest regards,
Alan
Alan Woods
Director, Compliance & Policy
Donuts and Afilias have rebranded to Identity Digital.
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