Summary

  • The GAC's 26 October Bali communiqué asks for industry-wide visibility into contracted parties' compliance with DNS-abuse obligations and reliable, reproducible measurement of registry and registrar mitigation.
  • ICANN's published enforcement reports count complaints, notifications and case outcomes. The 2024 registry agreement also requires periodic technical analysis and statistical reports on identified abuse and actions, supplied to ICANN on request. These records answer different questions.

A referee can keep a meticulous record of every whistle and still leave the audience guessing about the match. ICANN's DNS-abuse enforcement reports do valuable work: they show which complaints reached Contractual Compliance, which prompted investigation and how cases ended. At ICANN87, the Governmental Advisory Committee asked for a wider camera angle. Its Bali communiqué calls for industry-wide visibility into contracted parties' compliance and reliable, reproducible measurement of registry and registrar mitigation. ICANN or another provider could supply it.

The difference starts with the counting unit. ICANN explains that one complaint can allege several abuse types and involve several domains. A report marked phishing and malware can therefore contribute to two type totals while remaining one complaint. The same public series distinguishes incoming allegations, actionable notifications, complaints closed as unactionable and resolved investigations. These are useful stages in ICANN's own work. None is a census of mitigation across every contracted party.

The 2024 registry-agreement amendment points to another evidence stream. Registry operators must periodically examine whether domains in their TLDs are used for contractual DNS abuse, keep statistical reports on what they identify and the actions taken, and give those reports to ICANN on request. The same amendment requires appropriate action when a registry has actionable evidence, through referral to the sponsoring registrar or direct action. The registrar amendment separately requires prompt appropriate mitigation when a registrar has actionable evidence for a sponsored name. The periodic-analysis clause belongs to registries.

That arrangement leaves a reporting choice on the table. A registry can hold an internal account of identified incidents and responses; ICANN can ask for it. The monthly public compliance series instead follows reports that entered ICANN's complaint process. An operator with few complaints may have done diligent preventive work, received little scrutiny, or met reporters who gave up at the door. Complaint volume alone cannot sort those stories.

The GAC has identified the measurement gap without prescribing a league table. A credible public account would say whose work was observed, over what period, by which method, with what definition of an actionable report and what counted as mitigation. It would keep registry referrals, registrar interventions and case outcomes in their own columns. Only then could readers compare like with like. Counting whistles remains useful; the new question is how much of the field the microphone reaches.