Summary

  • The draft RIR Governance Document version 2, published by the NRO Number Council (also serving as the ASO Address Council) on 28 August 2025, proposed to replace ICP-2 (adopted 4 June 2001) as the instrument governing how Regional Internet Registries are recognized, operated and derecognized (NRO; ICANN public comment proceeding).
  • Under Section 2.3(a) of the version 2 draft, recognition required unanimous recommendation by the existing RIRs before referral to ICANN; a Candidate RIR rejected at that stage could seek a Recognition Review by an ICANN-appointed independent third party (draft text).
  • Derecognition could be initiated by any RIR or group of RIRs, by at least 25% of the subject RIR's members or 2,000 members (whichever is lesser), or by ICANN; approval required unanimous recommendation of the RIRs excluding the subject RIR, followed by a final ICANN decision (draft text).
  • Article 6.2 embedded a presumption in favor of rehabilitating a non-compliant RIR, with derecognition framed as a last resort; Article 6.3 defined the effects, including handoff of RIR services to a successor or Emergency Operator and loss of NRO membership (draft text).
  • Reconsideration of ICANN decisions relied on ICANN's then-existing procedures (Section 2.3(c)(ii)), and the public comment record shows commenters asking for a dedicated appeals procedure with defined timelines and an independent panel (ICANN summary report, 12 December 2025).
  • The NRO's own status reports record that no change was made to the deliberately high derecognition thresholds during the version 2 consultation cycle (Q1 2026 status report; Q2 2026 status report).

The governance question this draft raises is straightforward: which instrument grants the power to remove an RIR's recognized status, who can trigger that process, and who can challenge the result. Version 2 answered with a specific architecture — plural initiation, a peer unanimity gate, ICANN as final decision-maker, and review procedures borrowed from ICANN rather than built into the document itself. That architecture never took effect. On 28 July 2026 the ASO Address Council completed version 3 and handed the file to the NRO Executive Committee, and ICP-2 remains the instrument actually in force.

What the version 2 record preserves is a detailed map of how the numbering community's self-governance bodies think about their own vulnerability: the triggers, thresholds and review paths they were prepared to write for their own derecognition.

The version 2 draft was the product of a revision cycle that began with a principles phase, produced a first draft consulted in April–May 2025, and was published in its second form with a redline and summary rationale. The ICANN public comment proceeding ran from 28 August 2025 to 7 November 2025 and received 17 submissions. The revision record matters because the document would displace ICP-2 only if adopted by both ICANN and the RIRs — a condition never met during the draft's currency.

Recognition: unanimity and its review valve

Section 2.3(a) of the draft required the RIRs to unanimously recommend recognition of a Candidate RIR before the proposal could be referred to ICANN; if they did not unanimously recommend, the proposal was deemed rejected. Article 3.1 set the criteria such a recommendation would assess: regional qualification (a non-overlapping service region), resource holder support, community support including participation in policy development, capability against the document's operational requirements, no negative impact on the Internet Numbers Registry System, and material improvement over the existing state of affairs.

The unanimity rule gave every existing RIR a veto over a new peer. The draft's answer to that concentration was the Recognition Review (Section 2.3(a)(v)): a Candidate RIR that believed a non-recognition recommendation was made in error or without justification could petition for review by a qualified independent third party appointed by ICANN. If the review found a material error of fact or inadequate justification in a single dissenting RIR's position, that recommendation could be disregarded and the proposal referred to ICANN. The RIRs, however, were not obligated to change their recommendation.

The review therefore softened but did not remove the peer veto.

Derecognition: high thresholds, deliberate friction

Section 2.3(b) allowed a Proposal for Derecognition to be submitted by any RIR or group of RIRs, by members of the subject RIR holding at least 25% of total membership or 2,000 members, whichever is lesser, or by ICANN. A valid proposal had to state reasons and identify the specific provisions allegedly not complied with. Approval required unanimous recommendation by the RIRs excluding the subject RIR, with ICANN making the final decision.

The NRO's status reports record the rationale the Number Council gave for the design: derecognition is a final recourse and the trigger threshold is deliberately high. The Q1 2026 status report records the NRO NC's decision that there would be no change to the derecognition thresholds, and that a members' proposal falling short of 25% could still serve as a credible basis for other RIRs or ICANN to act. The same reports record a three-year minimum audit cycle and the NRO NC's decision not to make an audit a mandatory step within derecognition, since Article 6.2 already imposed a rehabilitation obligation.

Article 6.2 created a presumption in favor of helping a non-compliant RIR cure its non-compliance, with reasonable support from ICANN and the other RIRs, and framed derecognition as a last resort. Article 6.3 then specified the effects of a derecognition decision: the derecognized RIR must facilitate handoff of RIR services to a successor or interim entity — such as an Emergency Operator — named in the Notice of Decision; it ceases to be recognized and to provide RIR services; and it loses NRO membership. The Notice of Decision could prescribe a timeline and conditions before those effects took hold.

Appeals inside someone else's procedures

Section 2.3(c)(ii) provided that an RIR or Candidate RIR affected by an ICANN decision under the document could petition for review "in accordance with ICANN's then existing and applicable procedures." The document therefore contained no dedicated appeals mechanism, no timelines of its own, and no independent panel of its own. The 12 December 2025 ICANN summary report of the public comment process records commenters asking precisely for a dedicated reconsideration and appeals procedure, with defined timelines for submission and response, rights to present evidence, and an independent review panel.

The draft's answer was procedural dependence: the right to challenge existed, but its shape was defined by the reviewing body rather than by the reviewed instrument.

Supersession and the currency of the control surface

The status reports of Q1 and Q2 2026 (the latter signed 7 May 2026) document the NRO NC's response to the community input it received, including the threshold decisions noted above. On 28 July 2026, the ASO Address Council completed version 3 and formally delivered the Recommended Draft to the NRO Executive Committee, with responsibility for the document transitioning to the NRO EC. Version 3 replaced the recognition mechanism with a two-thirds RIR support threshold excluding the subject RIR, lengthened the audit cycle to five years, and emphasized rehabilitation as the preferred path in derecognition.

None of this changed the instrument actually in force. Until a final version is adopted by ICANN and the RIRs, ICP-2 of 4 June 2001 remains the governing document, and the draft's thresholds, review provisions and rehabilitation presumptions remain proposals — instructive ones, but proposals. Readers should treat the version 2 text as a record of institutional intent under negotiation, not as law of the numbering system.