Dear RPM IRT, 

We wanted to provide a written update on the progress of implementing the RPM Phase 1 Recommendations. Additionally, we’d like to clarify that although an RPM IRT session was initially scheduled for ICANN84, we’ve concluded that, given the current stage of our work, it would be more productive to connect individually while in Dublin. Accordingly, we will not be holding a formal session, but we will be on site and are happy to meet informally if you’d like to discuss any of the items below in more detail.

As you may be aware, we have completed implementation of the recommendations in Groups 2 and 3, which focused on developing educational materials to support RPM users and updating URS contact data. However, work on some of the remaining recommendation groups is still ongoing, as outlined below. 

Group 1 – Updates to RPM Procedural Documents

• TM-PDDRP: As noted in our message on 2 May 2025, the revised TM-PDDRP is now available here. 
  
  
• URS: While the URS Rules and Procedure are ready for publication, the URS High Level Requirements still require the following updates: 
  
  

1) OpenPGP Requirements: Updating the OpenPGP requirements in the URS High Level Requirements to align with the IETF’s recently adopted OpenPGP standard in RFC 9580. ICANN org’s technical services team is currently working with URS Providers to assess the complexity of implementing these changes. 

2) URS Registry Contact Process: Reflecting the current process that allows URS Providers to download up-to-date URS Registry Operator contact information. Although already in practice, this had not been incorporated into the URS High Level Requirements. 

Once the revisions above are incorporated into the IRT version of the URS High Level Requirements, we will share the updated URS High Level Requirements with you for review. After that, we will move forward with publishing the URS Rules, Procedure, and High Level Requirements. Publishing all three documents — the URS Rules, Procedure, and URS High Level Requirements — together will ensure consistency and clarity across the full set of requirements.

➤ Estimated Timing: We anticipate sharing the redlines for your review and publishing the URS Rules, Procedure, and High Level Requirements by Q1 2026.

• TMCH Requirements: Because the Next Round team is working on additional updates to the TMCH Requirements (e.g., terminology updates for consistency with the Base Registry Agreement, Launch Program adjustments, and other efficiency/operational enhancements), publication of the revised TMCH Requirements will be postponed to Q1 2026 to ensure they are available prior to the opening of the next round. Bundling these changes together will ensure a more comprehensive and streamlined update.
  Please note: The agreed-upon changes with the RPM IRT—specifically, those resulting from Trademark Claims Final Recommendations 2, 5, and 6—will remain unchanged.
  ➤ Estimated Timing: We anticipate publishing the revised TMCH Requirements Q1 2026.

Group 2 – Development of RPM Educational Materials

✅ Complete (See our note from 25 April 2025)

Group 3 – Development of URS Contact Data Process 

✅ Complete (See our note from 7 October 2025)

Group 4 – Collection of RPM Data

• TMCH Data: As noted in our 21 May 2025 update, we collaborated with the TMCH Validation Provider (Deloitte) to include the number of abused labels in the TMCH Monthly Reports published on ICANN.org. 

➤ Estimated Timing: This data point will first appear in the July 2025 report, which will be published here in November 2025 due to contractual requirements that delay publication until three months after the end of the reporting month.

• Trademark Claims Data Reporting: ICANN org is actively working to define the key data points to be included in the Trademark Claims data reports, determine an appropriate reporting frequency, and identify the tool or platform to be used for publishing the data. ICANN org will also work with ICANN-accredited registrars to begin publishing periodic reports—at least annually—on the number of Trademark Claims Notices sent to prospective registrants.
  ➤ Estimated Timing: We anticipate sharing a proposal for this work with the RPM IRT by Q1 2026.
  
  
• Publication and Search of URS Determinations: ICANN org collaborated with URS Providers to develop a proposal to standardize the publication and search of URS determinations that aligns with the operational capabilities of the URS Providers. The proposal includes an agreed upon common set of data fields used by all providers and using consistent terminology (e.g., “Disputed Domain Name(s)”). 

➤ Estimated Timing: Providers are requested to implement these changes by 30 January 2026.

• Survey of Trademark Owners’ and Registrants’ Experience with RPMs: On 22 August 2024, ICANN org issued a request for proposal (RFP) to select provider(s) to survey domain name registrants, Internet end-users, and trademark holders. The surveys have since been conducted, and the resulting reports are currently pending publication.

➤ Estimated Timing: These reports are scheduled for publication Q4 2025.

Group 5 – New Compliance Mechanism(s) 

• ICANN org is currently drafting a proposed process for handling complaints related to non-compliance by URS Providers, Registrars, or Registries with their procedural obligations under the URS Rules and Procedure. This includes identifying appropriate metrics for assessing compliance and consulting with relevant internal departments. ICANN org is also engaging with URS Providers to understand what complaint-handling mechanisms they already have in place, which will help inform the development of an effective and coordinated approach.
  ➤ Estimated Timing: The new process is expected to be shared with the RPM IRT and published in Q1 2026.

Given the estimated timelines above, we expect to conclude work on most of the listed items by Q1 2026. For additional information, please also refer to the RPM Phase 1 Estimated Timeline and the Implementation Plan.

Please feel free to reach out with any questions or to schedule time with us. 

Thank you!

Best,

Antonietta