At-Large Workspace: PSR on Expired Domain Deletion and Expired Registration Recovery Policies

Public Comment Close	Statement Name (Please click on hyperlink below for authoritative source)	Status	Assigned Working Group	Assignee(s)	Call for Comments Open	Call for Comments Close	Vote Open	Vote Close	Date of Submission	Staff Contact and Email	Statement Number

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Jun 30, 2025

PSR on Expired Dom2.ain Deletion and Expired Registration Recovery Policies

ratified

cpwg

Lead(s): @Alan Greenberg

Reviewers: @Alan Greenberg @Eunice Alejandra Pérez Coello

May 15, 2025

Jun 30, 2025

Jun 26, 2025

Jun 29, 2025

Jun 30, 2025

leon.grundmann@icann.org

AL-ALAC-ST-0525-03-00-EN

Where Community Input is Needed

The following text is from the public comment page and provides context around what is being commented on.

This Policy Status Report (PSR) examines how both the Expired Domain Deletion Policy (EDDP) and Expired Registration Recovery Policy (ERRP) perform based on three overarching goals: uniformity, clarity, and sufficient notice. The PSR identifies strengths and weaknesses, aided by quantitative data where possible, suggests how both the EDDP and ERRP could potentially be improved in the future. This will aid the Generic Names Supporting Organization (GNSO) Council in considering whether or not to undertake additional work on both the EDDP and ERRP.

ICANN org has carried out the work on this PSR, and part of this work involves gathering community input through the Public Comment process. Therefore, we would like to invite any individual or group with an interest in this PSR to provide comments to aid ICANN org in the evaluation and assessment of the EDDP and ERRP as they currently stand.

This Policy Status Report (PSR) examines how both the Expired Domain Deletion Policy (EDDP) and Expired Registration Recovery Policy (ERRP) perform based on three overarching goals: uniformity, clarity, and sufficient notice. The PSR identifies strengths and weaknesses, aided by quantitative data where possible, suggests how both the EDDP and ERRP could potentially be improved in the future. This will aid the Generic Names Supporting Organization (GNSO) Council in considering whether or not to undertake additional work on both the EDDP and ERRP.

ICANN org has carried out the work on this PSR, and part of this work involves gathering community input through the Public Comment process. Therefore, we would like to invite any individual or group with an interest in this PSR to provide comments to aid ICANN org in the evaluation and assessment of the EDDP and ERRP as they currently stand.

Executive Summary

A short executive summary, if the draft is ratified, will be placed here after the finalized document has been submitted.

The ALAC believes the PSR is a comprehensive review of the issues related to domain expirations and domain renewals but lacks historical awareness and contextual understanding. The ALAC notes that Section 2.2 highlights the problematic interaction between reseller contact roles and the reduced contact fields under the new Registration Data Policy. This creates a situation where the real registrant may never receive notice of a pending domain expiration especially if the reseller assumes the communication role but fails to act. Transparent pricing practices are essential to prevent registrants, particularly non-expert end-users, from encountering unexpected fees that may hinder their ability to retain or recover their domain names. The ALAC takes issue with possible multiple meanings of the undefined term “delete” in the Registrar Accreditation Agreement. Given the overlapping provisions, ambiguity and persistent registrant harms still seen unfolding, the ALAC recommends that a new policy development process be initiated to:

Consolidate the EDDP and ERRP into a single, comprehensive and enforceable policy reflecting current Registrar and Reseller practices;

Amend the RAA to clearly define critical terms such as “delete”,”notify” and “renewal” to prevent mis-interpretation;
Mandate that all registrar obligations are passed through to resellers and further down the reseller chain if applicable. Such obligations must ensure that the beneficial registrant is provided timely, consistent and accurate information; and
Conduct a thorough review of domain expiration and renewal issues as experienced by registrants and propose resolutions.

The ALAC believes the PSR is a comprehensive review of the issues related to domain expirations and domain renewals but lacks historical awareness and contextual understanding. The ALAC notes that Section 2.2 highlights the problematic interaction between reseller contact roles and the reduced contact fields under the new Registration Data Policy. This creates a situation where the real registrant may never receive notice of a pending domain expiration especially if the reseller assumes the communication role but fails to act. Transparent pricing practices are essential to prevent registrants, particularly non-expert end-users, from encountering unexpected fees that may hinder their ability to retain or recover their domain names. The ALAC takes issue with possible multiple meanings of the undefined term “delete” in the Registrar Accreditation Agreement. Given the overlapping provisions, ambiguity and persistent registrant harms still seen unfolding, the ALAC recommends that a new policy development process be initiated to:

Consolidate the EDDP and ERRP into a single, comprehensive and enforceable policy reflecting current Registrar and Reseller practices;

Amend the RAA to clearly define critical terms such as “delete”,”notify” and “renewal” to prevent mis-interpretation;
Mandate that all registrar obligations are passed through to resellers and further down the reseller chain if applicable. Such obligations must ensure that the beneficial registrant is provided timely, consistent and accurate information; and
Conduct a thorough review of domain expiration and renewal issues as experienced by registrants and propose resolutions.

FINAL VERSION SUBMITTED (IF RATIFIED)

The final version to be submitted, if the draft is ratified, will be placed here by upon completion of the vote.

FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.

https://docs.google.com/document/d/1QXIVmaqbspAdw-pmmYoD5cPKmG5G_x66zKgyE4En7Og/edit?usp=sharing

https://docs.google.com/document/d/1QXIVmaqbspAdw-pmmYoD5cPKmG5G_x66zKgyE4En7Og/edit?usp=sharing

DRAFT SUBMITTED FOR DISCUSSION

The first draft submitted will be placed here before the call for comments begins.

Bullet points:

This comments include the views of past members and the chair of the PDP leading to the ERRP.
Overall this is a comprehensive review of the issues related to domain expiration and renewal
Nevertheless, there is a lack of historical awareness. The report documents multiple cases of where there are inconsistencies between the two policies, and where the policies lack clarity.
- At least some of the inconsistencies are due to the resumption that ERRP was later and would supercede EDDP where applicable, but the implementation did not do that.
- The lack of clarity is often deliberate, because consensus could not be reached on more specific and clearer rules.
Section 2.2, page 20, lines 8-9 highlights the confusing situation of who to notify when resellers identify them selves as a contact and how that interacts with the new reduced list of contacts under the new Registration Data Policy. The end result is that the real registrant may never be notified of an expiration (described as a very prevalent issue).
The report mentions Registrars reassigning rights on expiration, but now not note that this started at the same time as EDDP “restored the expiration safety net”.
Report notes that resellers obliged to notify registrant of Registrar renewal prices, but not their own if higher!
The report notes that “Best Practices” may not be followed. Big surprise.
Report mentions confusion over the term “delete”. Although the term is not formally defined in the RAA, it is used consistently and should not be mis-interpreted.

Reasons why this is important to End Users

The reasons why this is important to end users is are te same ones as were sited when the ALAC requested the Issue Report in 2008 that lead to the ERRP.

This is important to end users who are also registrants. The ALAC has always taken the position that it supports end-user registrants except and unless the needs of these registrants are at odds with the needs of the larger community on non-registrant users.
Many end users rely on web site and resources which depend on domain names, and the loss of these names can impact many users
End-user registrants often have little Internet and DNS knowledge and financial resources and are thus more readily subject to behaviours which can lead to the loss of domain names. These domains are often non-commercial and public-service oriented and typically do not have the resources to use the UDRP or URS to protect their domains.

DRAFT STATEMENT: https://docs.google.com/document/d/1aOkMWzg9y-jk5c65ksvMu7sI8EZQmnGd9cAnxgHILuw/edit?tab=t.0