Of course, all requirements to validate a transfer should be established according the RAA rules.

Not all registrars provide RGP service, nor does Verisign require a registrar to be configured to do so. RGP is an optional registry service. There seems to be some creep between a registry providing a service, such as auto-renew and RGP, and registrars being required to perform additional tasks because the registry offers a service. The transfer requirements themselves are the source of one of the problems with "after expiration" transfers. A domain registrant will frequently purchase other services in addition to domain name registration, such as hosting, dns, or email. If (a) the registrant is using <user>@<domain>.<tld> as the administrative contact address for <domain>.<tld>, and (b) the registrant is using a registrar's bundled email service for that address, then the requirement to permit transfers after expiration of the domain name would appear to require registrars to continue to provide email service after expiration of the contract for email service. Otherwise, the registrant is not going to be able to confirm transfer via that email address to the gaining registrar, because email service was discontinued at the end of the contracted term. A registrar cannot be required to provide bundled services, such as email, for longer than the contracted term, unless the idea is to impose a requirement for maintenance of expired email accounts which is not imposed on ISPs or other email service providers. Some registrars change DNS on expired names and point them to a "Renew your domain name" page upon expiration of the domain name, so that the registrant can renew *during* the AGP and be notified of the expiration before the name slides into the more expensive RGP. Even if the admin contact email address through that domain is being serviced elsewhere, the email is going to be shut down. It is debatable whether operating in this manner helps more registrants become aware of the need to renew their domain names less expensively than using RGP. However, whether "renewal notification by DNS change) is or is not, a preferable "act now" notification to the registrant is purely a matter of opinion. Another class of "edge" cases at the end of the auto-renew grace period. Even if the registrant requests transfer to the gaining registrar near the end of the auto-renew grace period, the time periods between (a) the registrant's request, (b) the gaining registrar's confirmation, (c) transmitting the transfer to registry, and (d) the transfer at registry, are all variable. Hence, the domain name may be deleted by the registry at the end of the auto-renew period, even if the registrant requested transfer prior to the end of the auto-renew grace period. Alternatively, we could make the default registration term 13 months instead of 12 months. Then, no one could possibly fail to renew a domain registration, right?

Anyway, registrars will invoice/warning their clients BEFORE the end of the term.

There is an implicit requirement in the RAA for two reminders: ------ http://www.icann.org/nsi/icann-raa-04nov99.htm#IIJ Registrar shall register SLDs to SLD holders only for fixed periods. At the conclusion of the registration period, failure by or on behalf of the SLD holder to pay a renewal fee within the time specified in a second notice or reminder shall, in the absence of extenuating circumstances, result in cancellation of the registration. ------ In classic ICANN drafting form, it is ambiguous whether these reminders include pre-expiration reminders. Although the sentence begins with "At the conclusion of the registration period" the grammatical structure of the sentence attaches this time point to "shall... result in cancellation of the registration" as the "time specified in a second notice" may have been the time specified in a notice sent previous to "At the conclusion of the registration period". The other long-cycle obligation with respect to any registration is to retain records relating to that registration for a period of at least three years. Again, the primary problem here is one of accounting. Any audit of a registrar pursuant to, say, a public stock offering is going to require that a registrar be able to specify with precision what are its contractual obligations and what are the time periods associated with those contractual obligations. One cannot say, "I have a bunch of one year contracts, with continuing record retention obligations for three years, and my obligations under those contracts terminate 'a few days before 45 days after they say they expire'".