Summary

  • ICANN's preliminary Associated Domain Check proposal would oblige a registrar to investigate related names after actionable evidence of defined DNS abuse, but its rationale confines the duty to that registrar's own portfolio.
  • In a 22 September submission, M3AAWG asks for a specific exception: examine registrations at accredited sister registrars under the same operational control. That request is not adopted policy.
  • Wix's separate 23 September comment seeks examples and compliance expectations scaled to each registrar's actual systems and resources. The two submissions illuminate different limits; neither proves that affiliate data are already available or that any registrar failed a duty.

An abuse report can identify one domain and still leave a wider campaign untouched. ICANN's DNS Abuse Mitigation PDP 1 Initial Report addresses that problem by proposing an Associated Domain Check, or ADC: once a registrar has actionable evidence that a non-compromised name is being used for the DNS-abuse categories in its agreement, it would examine other names reasonably linked to the same activity. The draft protects legitimate holders against guilt by a shared nameserver, reseller or account signal. It calls for a proportionate inquiry using information normally and lawfully accessible to the registrar, not an indiscriminate sweep.

The line at issue is unusually precise. The report's rationale says the proposed policy requires checks within one registrar portfolio and does not require coordination across registrars. M3AAWG, the anti-abuse industry group, accepts much of the design but wants the line redrawn where two accredited registrars are Affiliates under the Registrar Accreditation Agreement and under common operational control. Sections 1.3 and 1.4 of that agreement already define an Affiliate by control or common control and an Affiliated Registrar as another accredited registrar in that relationship.

Those definitions identify a corporate link; they do not themselves create a new cross-portfolio ADC duty.

This is not the same as asking unrelated competitors to share records. Nor does the draft's reseller clause answer it. A reseller may carry out investigative steps, but the sponsoring registrar keeps responsibility for its own contract. A separately accredited affiliate has a separate portfolio and contract even if ownership overlaps. An affiliate rule would need to say when one registrar can lawfully see another's evidence, who opens and closes the case, and who can answer an ICANN compliance question. Common ownership does not establish common data access by itself.

Wix's comment presses on a different fault line. It supports the policy's broad intention but asks that “reasonable” investigation and “prompt” action be judged against the tools and information actually available to a given registrar, with illustrative, non-exhaustive guidance. Wix does not take a stated position on M3AAWG's affiliate extension.

Read together, the submissions expose a design test: an exception broad enough to prevent a corporate boundary from ending a justified search must remain specific enough not to demand inaccessible data, invite speculative association or turn a large registrar's tooling into the minimum standard for everyone.

There is no adopted outcome. Public Comment closes on 28 September, and ICANN says the working group will review submissions before a Final Report proceeds to the GNSO Council. Afnic's 24 September support for the draft as written is another submission, not a vote resolving the affiliate issue. This story concerns the scope of a proposed obligation, not a demonstrated cross-affiliate abuse case.

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