Draft Policy ARIN-2025-3

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Current Text (25 March 2025)

Problem Statement

Section 9 of the NRPM, Out of Region Use, requires organizations to use at least a /22 in the ARIN region before they can justify out of region use. This harms smaller organizations that have less than a /22 in region but do require some out of region use.

Policy Statement

Modify the following text in Section 9:

FROM:

IPv4: At least a /22 used in region.

TO:

IPv4: At least a /24 used in region.

RESULT:

Out of region use of ARIN registered resources are valid justification for additional number resources, provided that the applicant has a real and substantial connection with the ARIN region which applicant must prove (as described below) and is using the same type of resources (with a delegation lineage back to an ARIN allocation or assignment) within the ARIN service region as follows:

IPv4: At least a /24 used in region IPv6: At least a /44 used in region ASN: At least one ASN present on one or more peering sessions and/or routers within the region

Comments

In my experience when a company needs address space outside of the ARIN region without at least a /22 in region, they go to RIPE and acquire either PI or Legacy space (the least expensive option), often acquiring the space from ARIN sources.

In the case of an inter-regional ARIN to RIPE transfer, RIPE does require the recipient to demonstrate need, as required by ARIN. ARIN is losing registration of the block and annual fees, as well as the recipient transfer fee. Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry.

Looking back over the history of Section 9, it was first proposed by Terri Stumme in PROP 189 in May 2013, and was abandoned.

The Second proposal was by David Farmer in PROP 192 in January 2014 and was abandoned.

The third proposal was by Christian Tacit in PROP 219 in May 2015. It became draft policy ARIN-2015-5, implemented July 2016. The AC Shepherds were Tina Morris and David Huberman.

In looking over the discussions of the proposals, there was a concern before ARIN ran out of addresses in 2015 that foreign entities would set up shell companies in the ARIN region, looking for free addresses. Since ARIN is out of address space, that fear is no longer valid. If there is a fear of swindling the already crowded waiting list, it might be prudent to ban out of region needs demonstration from the waiting list.

Timetable for Implementation

3 months

Staff and Legal Review (23 February 2026)

Staff Understanding:

NRPM Section 9, Out of Region Use, for IPv4 addresses requires that to justify out-of-region use, an organization must utilize at least a /22 within the ARIN region before additional resources may be approved for use outside the region. Section 9 applies to IPv4 address requests in conjunction with section 4 “IPv4”, section 8.3 “Transfers Between Specified Recipients Within the ARIN Region”, and section 8.4 “Inter-RIR Transfers to Specified Recipients”. This section does not apply to section 4.4 or 4.10 space, these sections have their own restrictions.

Draft Policy 2025-3 proposes reducing the in-region IPv4 utilization threshold from a /22 (or equivalent) to a single /24. Under this change, an organization would need to demonstrate use of only one /24 within the ARIN region to justify receiving additional ARIN-issued IPv4 resources for use outside the ARIN region. Neither the current policy text nor this draft policy establishes any maximum on the amount of IPv4 space that may be justified to be used outside the ARIN region, so long as at least a single /24 is utilized within the ARIN region, meaning a single in-region /24 could, in practice, unlock requests for substantially larger blocks for deployment entirely outside the ARIN region. This draft policy does not modify the current section 9 threshold for Autonomous System Number and IPv6 usage.

In conjunction with section 4.1.8 “ARIN Waitlist”, an organization could request an initial /22 from the IPv4 waitlist with the intent to use a portion outside the ARIN region, provided they demonstrate efficient projected usage of one /24 within the ARIN region, and three /24s outside the ARIN region.

Staff anticipates this draft policy would significantly increase the volume of IPv4 waitlist requests. Because the policy requirements for an organization to justify an initial /24 are generally straightforward to meet, it is expected that more organizations may request a /24 primarily to qualify for additional ARIN-issued IPv4 addresses for out-of-region use. It is expected that this would result in more ARIN IPv4 space being used out of region.{}

Implementable as Written?:

Yes

Impact on ARIN Registry Operations and Services:

Anticipate increase to staff ticket workload

Legal Review:

No material legal issue

Implementation Timeframe Estimate:

3 months

Implementation Requirements:

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

Proposal/Draft Policy Text Assessed:

25 March 2025

History and Earlier Versions

Related Meetings