Recommended Draft Policy ARIN-2023-4

Modernization of Registration Requirements

Status: Under Discussion
Shepherds: Alicia Trotman, Daniel Schatte

Current Text (17 January 2024)

Problem Statement:

Registration is central to the value provided by ARIN to the community. Registry quality depends greatly upon the timely registration of reassignments from ISPs to end users. The motivation for registration has waned since the depletion of the free pool. At the same time, privacy laws have been introduced in many jurisdictions across ARIN’s service region which constrain registration in certain cases. This combination of forces has generally discouraged many ISPs from registering reassignments. Registration remains vital to a number of stakeholders, including law enforcement and network operators.

This proposal aims to modernize the registration-related policies in Section 4 by introducing language that is meant to make registration requirements more adaptable to changing privacy laws, while reminding ISPs of the importance of registration when feasible for the benefit of the community.

Policy Statement:

In section 4.2.3.7.1,

Replace

“Each IPv4 reassignment or reallocation containing a /29 or more addresses shall be registered via SWIP or a directory services system which meets the standards set forth in section 3.2.”

With

“Each IPv4 reassignment or reallocation containing a /29 or more addresses shall be registered in the WHOIS directory via SWIP, or a directory services system which meets the standards set forth in section 3.2, within 14 days.”

Retire section 4.2.3.7.2 Reassignments and Reallocations Visible Within Seven Days

Rename 6.5.5.1

From

“Reassignment Information”

To

“Reassignment and Reallocation Information”

In section 6.5.5.1,

Replace

“Each static IPv6 reassignment or reallocation containing a /47 or more addresses, or subdelegation of any size that will be individually announced, shall be registered in the WHOIS directory via SWIP or a distributed service which meets the standards set forth in section 3.2. Reassignment and reallocation registrations shall include each client’s organizational information, except where specifically exempted by this policy.”

With

“Each static IPv6 reassignment or reallocation containing a /47 or more addresses, or subdelegation of any size that will be individually announced, shall be registered in the WHOIS directory via SWIP, or a distributed service which meets the standards set forth in section 3.2, within 14 days. Reassignment and reallocation registrations shall include each client’s organizational information, except where specifically exempted by this policy.”

Retire section 6.5.5.2 Reassignments and Reallocations Visible Within Seven Days

Timetable for Implementation: Immediate

Comments:

None

Staff Understanding

This policy extends the requirement to create Reassignment and Reallocation records from 7 days to 14 days. The policy text is clear and understandable. Staff agrees with Legal’s comment.

Implementable as Written? Implementable with Legal’s concerns addressed.

Impact on ARIN Registry Operations and Services: None

Legal Review

Legal has a material legal issue with the inclusion of “to the extent permitted and manner provided by applicable law” in proposed sections 4.2.3.7.1 and 6.5.5.1. Section 1.1 of the Policy Development Process (PDP) addresses generally that all policies must be consistent with applicable laws and regulations. Since the goal of the PDP is to create and update the policies that ARIN uses to administer Internet Number Resources, any such reference to applicable law is unnecessary and could create ambiguity and inconsistencies.

Implementation Timeframe Estimate: Three months

Implementation Requirements:

  • Staff Training
  • Updates to public documentation
  • Updates to internal procedures and guidelines

Proposal/Draft Policy Text Assessed: 21 September 2023

History and Earlier Versions

History
Action Date
Proposal 5 June 2023
Draft Policy 25 July 2023
Revised 21 September 2023
Recommended Draft Policy 28 December 2023
Revised 17 January 2024

Board of Trustees

ARIN Public Policy Meetings