Summary

  • Version 2 (DRAFT) of the RIR Governance Document, published for review on 28 August 2025 by the NRO's Number Council, is intended to replace ICP-2, the 4 June 2001 criteria for establishing new Regional Internet Registries 1 3.
  • The most consequential change is procedural: where the first draft required unanimity among existing RIRs to recommend recognition of a new registry, Version 2 introduces a Recognition Review mechanism in which an independent third party assesses a candidate when unanimity fails (Section 2.3(a)) 4.
  • Version 2 lowers the thresholds at which a derecognition proposal can be raised — to 25 percent of an RIR's members or 2,000 members, whichever is lesser — while giving the affected RIR a formal right of public response 4 5.
  • The draft's structural spine is a lifecycle: recognition criteria and 'material improvement' expectations (Articles 2.5 and 3.1(f)), ongoing obligations with audits by an ICANN-appointed independent auditor at least every three years (Section 4.2), emergency continuity capped at 90 days (Section 5.1), a presumption in favour of rehabilitation over derecognition (Section 6.2), and the effects of derecognition, including resource handoff and loss of NRO membership (Section 6.3) 1 2.
  • A subsequent Version 3 draft has renumbered parts of this architecture — derecognition effects move from 6.3 to 6.8, rectification and periodic review from 7.2/7.3 to 7.3/7.4 — and moved the regular audit cycle from three years to five, which means any citation of Version 2 provisions must state which version is meant 8 9.

A replacement drafted for a quarter-century-old rulebook

The instrument at stake succeeds a document older than most of the organisations it would now govern. ICP-2 — 'Criteria for Establishment of New Regional Internet Registries' — was adopted on 4 June 2001, when five RIRs were seen as the settled architecture of number-resource administration 1 7. The governance project that produced Version 2 is formally titled the 'Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries'. The title itself carries information: the April first draft had used 'Maintenance' where Version 2 uses 'Operation' 1 7. That word change tracks a substantive one — the draft no longer assumes an RIR, once recognised, simply persists; it assumes an RIR must continuously satisfy conditions whose failure has defined consequences.

The process that produced Version 2 is documented on both sides. The first draft was published on 14 April 2025, and a community consultation ran through ICANN's Public Comment process alongside RIR-organised consultations from 14 April to 27 May 2025. The NRO's own Round 2 consultation summary records that feedback; Version 2 was then developed from it 3 6. RIPE NCC, one of the five RIRs, published its own notice of the Version 2 summary and rationale on 28 August 2025, which is itself evidence of how the RIRs are presenting the revision to their member bases 6.

What Version 2 actually changes

The NRO Number Council's summary of differences and rationale sets out the delta between the drafts, and the delta clusters into four groups.

First, recognition. The first version required unanimity among existing RIRs to recommend recognising a new registry — in effect, a five-member veto. Version 2 introduces a Recognition Review (Section 2.3(a)): where unanimity fails, an independent third-party review assesses the candidate 4 5. The draft also adds a 'material improvement' criterion (Sections 2.5 and 3.1(f)), meaning a candidate is evaluated not only against fixed criteria — regional qualification, resource-holder support, community support (Section 3.1) — but against demonstrated improvement relative to some baseline 4.

Second, implementation discipline. Version 2 adds Implementation Procedures (Section 1.3) with an explicit constitutional constraint: they cannot contradict or override any term of the Document itself 4 5. This is a subordinate-law clause, the kind of drafting that determines who wins when operational practice and instrument text diverge.

Third, exit conditions. Derecognition proposal thresholds move to 25 percent of an RIR's members or 2,000 members, whichever is lesser, with the affected RIR entitled to respond publicly 4. The draft counters this with a presumption in favour of rehabilitation over derecognition (Section 6.2) — derecognition is framed as a last resort 1. Section 6.3 then enumerates the effects: handoff of number resources, cessation of the RIR's service responsibility, loss of NRO membership, and a possible implementation timeline 2.

Fourth, ICANN's role. Version 2 expands it in several directions — ICANN publishes objections and reviews, may initiate derecognition proposals, may initiate ad hoc audits, and must consent to emergency-continuity arrangements (Sections 2.3(b), 2.4, 2.8, 5.1) — and adds a general duty of good faith and fair dealing among the parties 4 5.

The obligations architecture: audits, continuity, amendments

Section 4.1 sets out ongoing operational requirements — financial and operational independence, governance, transparency, performance, continuity, meetings. The enforcement backstop is Section 4.2: periodic audits at least every three years, performed by an independent auditor appointed by ICANN 2. Version 3's changelog later moved that cycle to five years, so the three-year interval is a Version 2 position, not a settled one 9.

Section 5.1 introduces the emergency-continuity mechanism: if an RIR fails, a temporary emergency operator can be installed, but only with the unanimous agreement of the other RIRs and ICANN, and only for up to 90 days unless renewed 2 1. Read together with the derecognition provisions, this is the draft's answer to the question ICP-2 never posed: what happens in the interval between failure and formal exit, when millions of resource holders still need registry services.

The amendment rule preserves incumbency at the constitutional level: Article 7.1 requires unanimous agreement of ICANN and the RIRs, after consulting their respective communities, to approve amendments. Section 7.2 addresses rectification — a clause Version 3 renumbered to 7.3, with Periodic Review shifting from 7.3 to 7.4 1 8. The Number Resource Organization itself functions as the RIRs' coordinating body, established by the NRO Memorandum of Understanding in 2003, which is why its Number Council is the drafting and publishing authority here 8.

Evidence boundaries

Three limits should be stated plainly. The full Version 2 text, including any in-page change tables, was not rendered in full in the sources retained for this article; provision-level citations rest on the published draft PDF and the NRO and ICANN process pages. The 'final disposition' of the Round 2 public comments does not appear verbatim in any retrieved source — the consultation is documented, its outcomes are not itemised here. And Version 3's publication date is not stated in the retained excerpts, so Version 3 material is used strictly comparatively, as a numbering and audit-cycle cross-reference 8 9.