GNSO Council Registration Data Accuracy Small Team

GNSO Council Registration Data Accuracy Small Team (often referred to as the Council Accuracy Small Team or the GNSO Council Small Team on Registration Data Accuracy) is a temporary group of GNSO Council members tasked with reviewing community input on registration data accuracy and recommending next steps to the Council.

The small team was convened on May 15, 2025 to “closely review the results of the registration data accuracy input assignment and provide a recommendation to the Council on how to proceed”. Its work builds on earlier GNSO discussions of registration data accuracy, including the Registration Data Accuracy Scoping Team, which was asked to address the effects of GDPR on Registration Data accuracy requirements and the Whois Accuracy Reporting System (ARS), and on the subsequent “Accuracy Assignment”, which included questions about the urgency of further work in consideration of the EU’s NIS2 law.

Background

Registration data accuracy has been a longstanding topic in ICANN, featuring in the Registrar Accreditation Agreement (RAA), ICANN Contractual Compliance programs, and several review team and advisory outputs. In 2021 the GNSO Council created the Registration Data Accuracy Scoping Team to look holistically at accuracy obligations, enforcement, measurement, and potential improvements, including a possible successor to the Whois Accuracy Reporting System (ARS). The Scoping Team’s instructions emphasised the impact of GDPR on data publication and access, the pause of ARS due to lack of accessible data, and the need to consider how accuracy could be measured under the new legal and technical environment.

As part of the follow-up to this work, the Council developed an "Accuracy Assignment" (sometimes called the "Accuracy Framing Assignment"), which set out a series of “threshold questions” for ICANN org and the community. These questions asked, among other things:

• what specific problems are caused by inaccurate registration data and who is affected;
• how urgent further work on accuracy is, particularly in light of NIS2 and other legislation;
• what tools, such as audits or ccTLD practices, might be viable approaches; and
• how to frame any future policy or data-gathering effort on accuracy.

During ICANN 80, the GNSO Council reviewed data accuracy and considered alternative paths forward. On October 25, 2024 it circulated a draft concept proposal and the Accuracy Assignment with threshold questions to ICANN org and, subsequently, to interested Stakeholder Groups, Constituencies and Advisory Committees (SG/C/ACs). ICANN org responded in December 2024, and by mid-February 2025 eight community groups (RrSG, RySG, NCSG, IPC, ISPCP, GAC, BC and ALAC) had submitted written input, later joined by SSAC.

Earlier work on measuring accuracy, including ARS and elements of the Scoping Team’s data-collection ideas, had been slowed or stalled by GDPR-related limits on sampling registration data, which made it difficult to obtain reliable datasets without infringing data protection rules. Community discussions leading into ICANN 82 highlighted these practical constraints and the need for a more targeted, consensus-driven approach to accuracy that could still inform future policy or operational work.

Creation and Mandate

On March 12, 2025, the GNSO Council agreed to task a dedicated small team of Council members to work on registration data accuracy. The Council’s resolution directed the small team to use the Accuracy Assignment inputs as its primary basis for analysis. An updated written assignment for the small team was approved by the Council by non-objection on April 28, 2025 and documented in the "GNSO Council Small Team – Registration Data Accuracy Work Assignment Overview".

According to the assignment, the small team is tasked to:

• review the written input received from ICANN org and community groups on the Council’s threshold questions on accuracy;
• provide a detailed summary of this input, taking into account other relevant sources such as:
  • the INFERMAL study on maliciously registered domains,
  • work of the EU NIS2 cooperation group, and
  • implementation work around RDS-WHOIS2 Recommendation CC.1; and
• recommend to the Council how best to progress work on registration data accuracy, including options such as:
  • relaunching a scoping team with an updated assignment,
  • requesting an "Issues Report" to initiate a Policy Development Process, or
  • commissioning additional studies, including specifying their form and purpose.

The target in the assignment form was for the small team to share its findings and recommendations with the Council by ICANN 83, held in June 2025.

Composition

The Registration Data Accuracy Small Team is composed of Council members (or their alternates) drawn from across the Contracted Parties House, the Non-Contracted Parties House, and the At-Large community. According to the Council workspace and the assignment form, membership includes:

It is chaired by Paul McGrady.

• Peter Akinremi
• Damon Ashcraft
• Farzaneh Badii
• Manju Chen
• Jennifer Chung
• Justine Chew
• Sam Demetriou
• Greg DiBiase
• Sebastien Ducos
• Prudence Malinki
• Lawrence Olawale-Roberts

ICANN org support for the small team is provided by Caitlin Tubergen and Feodora Hamza.

Work and Timeline

Launch and early meetings

The Registration Data Accuracy Small Team began meeting on May 15, 2025. Its initial work focused on orienting members to the assignment, agreeing on a meeting cadence, and developing a work plan for reviewing the Accuracy Assignment responses and related material.

During ICANN 83 in Prague, the small team provided a public progress update to the GNSO Council. The slides presented at that session summarized where community inputs showed clear divergence and where there was convergence. Areas of divergence included, for example, whether inaccurate registration data is currently a major problem, whether existing RAA accuracy requirements are sufficient, whether additional policy work is urgently needed, and whether "accuracy" should go beyond contactability to include some form of identity verification or explicit linkage to DNS abuse.

The same presentation identified that, despite disagreement on some questions, there was broad acknowledgement among respondents that:

• accurate registration data is important to the DNS ecosystem;
• current policy and contractual requirements in the RAA and related policies provide a starting point for any working definition of “accuracy”; and
• more data would be helpful to inform future decisions on whether and how to strengthen accuracy requirements.

These shared elements became the basis for identifying "golden nuggets" - specific areas where further analysis or action might command relatively broad support.

Focus Areas

At ICANN 83, the small team highlighted three initial areas for further investigation ("golden nuggets) based on alignment in the inputs it received:

• Validation and verification timelines: considering whether the timeframe for registration data validation and verification should be shortened, in light of findings from the INFERMAL study suggesting that performing verification before or during registration can significantly reduce malicious registrations.
• Registrant education tools: exploring user-friendly educational material before, during and after registration, to explain:
  • the importance of accurate and up-to-date registration data across the domain lifecycle,
  • how registrant data is protected, and
  • the consequences of providing inaccurate data (including potential suspension).
• RDDS notation for accuracy-related suspensions: examining follow-up work on RDS-WHOIS2 Recommendation CC.1 to develop notation in Registration Data Directory Services (RDDS) outputs to signal when a domain has been suspended due to inaccurate registration data.

Summary Report and Council Action

By July 2025 the Small Team had consolidated its work into a “Summary Report on Registration Data Accuracy”, dated July 31, 2025. The report set out four recommendations intended to guide the GNSO Council’s next steps on accuracy and to inform the ICANN Board and broader community. While the detailed text of the recommendations is contained in the report itself, public presentations and community summaries indicate that they build on the focus areas identified earlier: validation/verification timing, registrant education, treatment of accuracy-related suspensions in RDDS, and the need for further data-informed discussion about the scope and timing of any policy development on accuracy.

On August 14, 2025, the GNSO Council adopted a motion titled “Motion to Approve the Council Small Team on Registration Data Accuracy’s Recommendations”. In that resolution, the Council

• noted the earlier steps leading to the small team’s creation, including the 2024 drafting effort on threshold questions and the responses from ICANN org and eight community groups;
• recorded that the small team had developed four recommendations based on its review of these inputs and other sources; and
• formally approved the four recommendations in the small team’s Summary Report.

Reports to other parts of the community, such as the GNSO Liaison reports to the ALAC, later highlighted the adoption of the Registration Data Accuracy recommendations as one of the GNSO Council’s key accomplishments in the period between ICANN83 and ICANN84.

Generic Names Supporting Organization. Develops and recommends to the Board substantive policies relating to generic top-level domains and other responsibilities set forth in the Bylaws (ICANN Bylaws).

Europe, according to the ICANN Geographic Regions (ICANN Geographic Regions).

Registrar Accreditation Agreement

General Data Protection Regulation

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