I&JPN comments on: ICANN Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations.

Published on
June 20, 2023

The Secretariat of the Internet & Jurisdiction Policy Network (I&JPN) has submitted detailed public comments to the Internet Corporation for Assigned Names and Numbers (ICANN) regarding the proposed amendments to the base generic Top Level Domains (gTLD) Registry Agreements (RA) and Registrar Accreditation Agreements (RAA) that seek to modify DNS Operators’ contractual obligations regarding DNS abuse. 

I&JPN's Secretariat strongly encourages the adoption of these amendments, as this will constitute a litmus test for the capacity of the multistakeholder approach to enacting meaningful binding rules. 

For a long time, arguments about the meaning of “DNS abuse” prevented fruitful discussions within the ICANN community on when and how it is appropriate to act at the level of the DNS to address abuses online. 

After long and often conflictual discussions around the very notion of DNS Abuse, these concise and balanced amendments set very specific, yet flexible, responsibilities for contracted parties when dealing with abuse reports.

The proposed amendments aim to clarify crucial points, through concise and balanced formulations related to DNS abuse. These comments seek to address the challenges and ambiguities surrounding the definition and mitigation of DNS abuse, promoting a more secure and reliable online environment.

By clarifying the scope of abuses, establishing specific responsibilities for contracted parties, and emphasizing the importance of prompt action and evidence-based decision-making, these amendments strive to strengthen the effectiveness of combating DNS abuse within the ICANN community.

The development of these balanced amendments represents a significant achievement resulting from the dedicated work of the I&JPN Secretariat's Domains & Jurisdiction Contact Group over the past five years.

I&JPN strongly encourages contracted parties to adopt these comments to embrace these comments as a crucial indicator of ICANN's capability to establish meaningful binding rules. Failure to gain sufficient support may reinforce the perception that the multistakeholder approach lacks the power to impose necessary constraints on irresponsible actors. On the contrary, their adoption will signify a strong commitment from DNS operators to fulfill their responsibilities and showcase ICANN's capacity for progress in addressing this critical issue.

  • Read the complete document with the proposed amendments here