TLD Newsflash

Registrar Accreditation Agreement (RAA) Abuse Obligations

New obligations and processes coming for responding to domain name abuse:

ICANN’s Board of Directors will soon vote on contract amendments which were approved late last year by the gTLD registries and ICANN-accredited registrars. We anticipate that the vote, when taken, will pass and that implementation of the new obligations will enter into force in March or April of 2024.

The new obligations for gTLD domains

  • “DNS Abuse” is defined as “malware, botnets, phishing, pharming, and spam (when spam serves as a delivery mechanism for the other forms of DNS Abuse listed in this Section) as those terms are defined in Section 2.1 of SAC115 (<>).”
  • When an ICANN-accredited registrar receives “actionable evidence” of a registered name under its management being used for DNS Abuse, the registrar is obliged to “promptly take the appropriate mitigation action(s) that are reasonably necessary to stop, or otherwise disrupt, the Registered Name from being used for DNS Abuse.”

What will change

  • If Com Laude receives an abuse complaint in respect of one of your registered domain names, we must push you to be prompt and responsive in dealing with that complaint. Previously our Domain Strategist team would have notified you of an abuse complaint and left this for you to address via your usual processes, usually without follow-up.
  • The new obligations will require us to follow up with you within a short period of time to confirm that you have evaluated the complaint and taken steps, where reasonably necessary, “to stop, or otherwise disrupt” the abusive activity.
  • Quite simply, our failure to follow up in this manner could put Com Laude’s ICANN accreditation at risk. The compliance burden for you and us increases, but we are in this together and will work with you to evolve.

Why these amendments are positive

These changes are, we believe, good news for our clients from the perspective of managing their intellectual property rights, as abuse complaints you and your organizations make against activity falling within the definition of “DNS Abuse” above should receive more prompt and responsive attention.

Impact on ccTLD domains

While the new obligations described above are targeted at gTLDs, combatting abuse appears to be a worldwide trend. Some ccTLD have already begun taking more aggressive stances, and we anticipate that more will do so in the future. This is very likely to be a major theme in the domain name world throughout 2024.

Next steps

We are doing our best to navigate this new world and keep you informed to minimise the risk to you and your domains. Once ICANN’s Board of Directors votes and we have a timetable for the implementation of the new obligations, we will post another newsflash to alert you. If you have any questions or concerns about these changes, please contact your Domain Strategist to discuss further.