The turd polishers at ICANN have produced yet another highly polished turd of a report regarding domain name transfer policy, that is open for public comments until 23:59 UTC time on Monday June 16, 2025 (i.e. less than 24 hours from the time of this blog post). The report is being voted upon by the ICANN Board, so this is really the final opportunity to go “on the record” with your input (which will in all likelihood be completely ignored, but some of us still choose to submit comments regardless).
Our complete submission is now visible on ICANN’s website here, or you can read the main 19 page PDF here.
For a small taste of the contents of the document, here’s the “Conclusion” section from the final page of the PDF:
The analysis presented herein underscores that the “push-based” transfer system and enhanced WHOIS transparency within the Losing FOA are not merely incremental improvements but represent fundamental shifts necessary for establishing robust domain name security and ensuring comprehensive registrant protection in the evolving digital landscape. These proposals address inherent vulnerabilities in the current transfer policy that the Transfer Policy Review Working Group’s Final Report has, regrettably, failed to adequately address.
The working group’s dismissal of the push-based system due to a stated preference for “incremental change” and perceived workload reveals a systemic bias within ICANN policy development towards minor adjustments over truly transformative ideas. This incrementalist approach inherently limits ICANN’s capacity to achieve optimal security and fulfill its mandate, highlighting the critical need for Board intervention. Furthermore, the dominance of registrars within this working group and the referral of critical proposals to “Tech Ops,” which is not a true multistakeholder forum, point to a fundamental challenge within ICANN’s multistakeholder model regarding the perceived balance of power and influence. The Board’s decision on this report will therefore signal its commitment not only to domain transfer security but also to the integrity of genuine multistakeholder engagement and registrant representation, thereby impacting ICANN’s overall legitimacy and accountability.
Therefore, it is strongly urged that the ICANN Board reject the Transfer Policy Review Working Group’s Final Report in its current form. The Board should instead mandate further work by a truly multistakeholder body, with explicit instructions to thoroughly evaluate and prioritize the push-based transfer system and the enhanced WHOIS transparency proposal within the Losing GOA. This decisive action would demonstrate a commitment to innovation and prioritize registrant security over incrementalism or the vested interests of specific contracted parties. By taking such a course, the ICANN Board would not only address critical security deficiencies but also reaffirm its dedication to its core mission and the principles of a balanced, accountable multistakeholder model.
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