Dear Isabelle, dear IRT Members, We discussed the state of play and the latest text in the GAC small team on registration data and we find the work of the IRT is going in the right direction. I am conveying the appreciation of the whole team for the good cooperation in the IRT group. Before the text is finalised and sent for public comment, we would propose that one outstanding element be addressed concerning the institutionalisation of the authentication system. We believe the latest text circulated by ICANN org attempts to achieve a shared goal – that is reaching certainty in the implementation and enforcement of the policy. However, we are concerned that as the text stands now it might imply that a new policy development process would be required to include the authentication system in the registration data policy. This is why we propose a text that we believe provides more flexibility. You will find more details in the rationale attached to the proposed text, but from the GAC perspective a new PDP is neither necessary nor desirable. We are already at the stage of implementing consensus policy (EPDP Phase 1 recommendations) and it was upon request of the ICANN Board and the GNSO Council that the issue of authentication was addressed in parallel to the establishment of a timeline. The GAC has agreed to this request and accepted that the PSWG would devote resources to work with relevant parties to establish a mechanism that when ready should be embedded in the policy (and that as any system can be improved and expanded over time). We also offer a small suggestion concerning the text on the timeline, in case it would provide more clarity. Looking forward to meeting some of you in Dublin at ICANN84, where perhaps we could also exchange on this subject. Kind Regards, Gemma on behalf of the GAC Small Team [cid:image001.gif@01DC3F8C.95D248F0] GEMMA CAROLILLO Deputy Head of Unit Future Internet European Commission DG Communications Networks, Content and Technology Rue de la Loi, 51 1000 Brussels, Belgium gemma.carolillo@ec.europa.eu From: Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Sent: Friday, October 3, 2025 10:54 PM To: irt.regdatapolicy@icann.org Subject: [IRT.RegDataPolicy] Updated October 2025 ICANN org proposed language for IRT feedback prior to public comment period. Dear IRT Members, I want to sincerely thank you for your contributions and collaboration thus far. It has been a pleasure working with you over the past six months. As promised, attached are the clean and redline versions of the draft proposal language. Please provide your feedback no later than Friday, 17 October. Our goal is to subsequently publish this language for public comment on Wednesday, 22 October. Your feedback prior to the public comment period will be incorporated into an updated rationale paper, which will be published alongside the proposal during public comment as an additional resource for commenters, to show the discussions that have taken place in regard to the timeline for responding to urgent requests. As a reminder, the public comment period will provide a transparent opportunity for IRT members as well as other stakeholders to share feedback on the proposal. The public comment also provides the opportunity to raise alternative suggestions that have not already been discussed during the urgent request related IRT sessions. Clean Version of Proposed Language<https://urldefense.com/v3/__https:/docs.google.com/document/d/1Yao6h5gKbmBcX...> Redlined Version of Proposed Language.<https://urldefense.com/v3/__https:/docs.google.com/document/d/1EZpHwFWDM6lEg...> · Note that both versions do not include previous IRT feedback to make updates and ICANN org rationales easier to find. If you’d like to review previous IRT feedback, you can do so here<https://urldefense.com/v3/__https:/docs.google.com/document/d/1T2CMza4whggkv...> which also includes the previous (August 2025) Iteration of the proposed language.<https://urldefense.com/v3/__https:/docs.google.com/document/d/1T2CMza4whggkv...> Thank you again for your time, effort, and thoughtful contributions. I look forward to your feedback. Kind Regards, Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<https://urldefense.com/v3/__http:/www.icann.org__;!!DOxrgLBm!DRrgcb1H4tJB9WP...> Mobile: +1 310 266 7469
