Summary

  • On 13 August 2026, the ccNSO Council discussed a 2007 geographic-region self-selection procedure that no longer fully reflects the ICANN Bylaws, including their recognition of multiple ccTLD managers from one Territory.
  • The old procedure lets the IANA administrative contact submit for “the ccTLD manager”; the current Bylaws distinguish manager, Representative, Territory and Emissary. A replacement must state whose region is being selected and whose consent can bind the choice.
  • The assignment is for ccNSO governance only. It does not decide a ccTLD delegation, IANA service access, operational control, sovereignty or geographic classification across every ICANN structure.

A singular form now meets a plural institution

The trigger was mundane: migration of the ccNSO website brought an old procedure and form back into view. A 30 July Council-list message said that both had been overtaken by updates to the ICANN Bylaws. An official At-Large report of ccNSO Council meeting 232 says the Council discussed the issue on 13 August and asked the Secretariat for a report setting out the advantages and disadvantages of the existing procedure and possible changes.

No replacement has been adopted in the records reviewed for this Article. That matters because the gap is easy to overstate. There is no published finding that a past Council election was invalid, no identified manager saying it was denied a regional choice, and no evidence of a current dispute between managers in one Territory. The present decision is a design task before a conflict makes each undefined term consequential.

The 2007 procedure addresses a special case. Some ccTLD managers are assigned to an ICANN geographic region by the citizenship criterion rather than by the physical location associated with the Territory. If such a manager is a ccNSO member, it may ask to self-select a region. The request is submitted by the IANA administrative contact and supported by a letter from the relevant government or public authority. IANA checks the requestor, the Secretariat checks eligibility, regional liaison staff check the supporting authority, and the Council decides.

The document repeatedly describes one manager. It also says the resulting assignment applies only in ccNSO matters, generally cannot be changed for five years except in extraordinary circumstances, and depends on continuing Council adoption after annual review. Those limits remain important. The weakness lies in the procedure’s model of the applicant.

Manager, Representative and Emissary are not interchangeable

Current Article 10 of the ICANN Bylaws contains a more articulated representation chain. Each ccTLD manager may designate a person, organisation or entity as its Representative. If it does not, the administrative contact in the IANA database is deemed to be its designate. Where the Territory has only one manager, that Representative is also its Emissary.

The structure changes when a Territory has two or more managers. Those managers must appoint one of their Representatives as the Emissary. If they do not make an appointment, the Bylaws provide a default based on the longest-standing ccNSO member manager. The Emissary casts the Territory’s one vote in the votes specified by Article 10.

This is not wordplay. A Representative expresses one manager’s role. An Emissary is the single voting interface for all managers from the Territory in a defined set of ccNSO decisions. The IANA administrative contact may be deemed a manager’s Representative, but that does not automatically make the contact authorised to commit every other manager from the same Territory to a five-year regional choice.

The old form’s singular channel therefore leaves at least three possible readings. The region might attach to each manager separately. It might attach to the Territory and cover all its managers. Or it might be a contextual attribute used only when a particular ccNSO rule asks where the Territory sits for nominations, voting or quorum. Each reading produces a different consent rule and a different failure mode.

Region is an input to the ccNSO’s allocation of power

The choice is not ceremonial. The ccNSO Council includes three members selected by ccNSO members within each of ICANN’s five geographic regions. Current election guidance says one seat in each region is selected every year. Article 10 also requires a Council candidate’s nominator and seconder to be from the same region but different Territories, and the election uses votes cast through Emissaries.

Region also appears elsewhere in the ccNSO’s authority machinery. Member-triggered votes and quorum tests can depend on support distributed across different Territories or regions. Board-seat nominations use the Emissary model even when the decisive electorate is not organised as five separate regional races. A classification can therefore affect who may nominate, who may second, which seat is being filled, whether a geographic threshold is met and which version of the membership roll is valid for the act.

That is why the Secretariat’s options paper should map every affected function before recommending a new submission channel. A clean online form connected to an undefined unit would preserve the underlying ambiguity with better typography.

The map should also state what the choice does not affect. The old procedure limits the assignment to ccNSO-related matters. Current Bylaws further say that membership in the ccNSO or a regional organisation is not a condition of access to or registration in the IANA database and is not a condition for receiving IANA services. Regional self-selection is not a transfer of a ccTLD, a root-zone instruction, a finding about sovereignty or a licence to operate a national domain.

The replacement needs a consent rule, not merely a submitter

A defensible procedure begins by naming the unit. The application record should list the Territory, the ccTLD or ccTLDs involved and every current manager within scope. It should show the existing geographic classification, the requested ccNSO classification and the specific Council, nomination, voting or quorum rules that will consume it.

Next comes authority. Each manager’s Representative and the Territory’s current Emissary should be taken from a dated record. The application should identify who initiated it, which managers affirm it, who objects and who has not responded. If the procedure requires unanimity, it should say so. If the Emissary may submit after a defined internal decision, that power must be explicit. If disagreement sends the request to the Council, the standard and evidentiary burden need to be public. Silence should not become consent by accident.

The government or public-authority letter also needs a bounded purpose. In the 2007 design, it supports the manager’s request and the relevant geographic connection. In a multiple-manager setting, one letter cannot silently answer whether each manager consented or whether the Emissary had authority under the ccNSO Bylaws. Public authority evidence and member-governance authority are different inputs.

Finally, the effective date has to meet the election calendar. A region change approved after nominations open could alter candidate eligibility or the seat to which a candidacy belongs. One approved between the voter-roll freeze and the ballot could disrupt the electorate. The procedure should specify a cutoff, the first affected election cycle and how a pending application is treated. The five-year restriction needs an equally clear start time and a rule for manager changes, new ccTLDs or a later split in consent.

Publish the decision record without publishing personal contacts

The useful public object is a versioned region-selection record. It can name the Territory, managers, ccTLDs, requested region, affected ccNSO functions, consent state, decision authority, reasons, effective cycle and expiry of the five-year restriction. It should retain prior versions, corrections, dissents and any review.

The record need not expose an administrative contact’s personal address or the private exchanges by which managers chose an Emissary. It can point to the authoritative role record and state that the required appointment or consent was verified by the Secretariat. Supporting government correspondence can be summarised by issuer, date and proposition established, with sensitive contact data redacted.

This separation protects both legitimacy and minimisation. Members can reconstruct why a nominee belonged in a regional contest or why an Emissary could cast a vote. At the same time, the public page does not become a copy of IANA contact data or an archive of personal correspondence.

The current event is an opportunity to write the join before the databases are connected. The ccNSO already has rules for managers, Representatives, Emissaries, Territories and regions. What it lacks is an explicit, current rule for moving a self-selection through those roles. A plural institution cannot safely inherit a singular form’s authority assumptions.

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