Summary

The operative instrument is still twenty-five years old

Which document actually grants authority over RIR recognition, maintenance and derecognition is the first question any operator, lawyer or governance practitioner should ask, and the public record gives a clear answer. ICP-2 was developed through ICANN's Address Supporting Organization with the assistance of APNIC, ARIN and RIPE NCC, and on 4 June 2001 the ICANN Board accepted it "as a statement of the essential fundamental principles required for recognizing and evaluating new Regional Internet Registries." https://aso.icann.org/icp-2-review/ That acceptance is the operative grant. No subsequent instrument in the public record has superseded it.

What has changed since 2001 is the drafting pipeline that may eventually replace it. In October 2023 the NRO EC tasked the NRO NC, acting as the ASO AC, with managing the review and update of ICP-2, focused on governance, ecosystem and operational criteria, the lifecycle of RIR recognition, and principles for potential derecognition. https://www.ripe.net/community/nro-nc/icp-2-review/ The date of that tasking is itself recorded inconsistently across the bodies' own pages — October 2023 on the RIPE NCC and ASO pages, November 2023 on the NRO process page, 25 October 2023 in the ICANN 84 GAC/ASO presentation — a minor but instructive discrepancy in how the coordinating institutions keep their own record. https://aso.icann.org/rir-governance-document-version-2-status-report-may-2026-now-available/

The drafting record, quarter by quarter

The process ran through a principles questionnaire (October–December 2024), a summary of responses (February 2025), a first draft available for public comment (April–May 2025), and version 2 of the "Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries," published 28 August 2025 with a consultation and ICANN Public Comment window running to 7 November 2025 and 17 submissions received. https://aso.icann.org/icp-2-review/ Status reports through 2026 tracked work between rounds: a Montevideo workshop, an in-person meeting at ICANN 85 in Mumbai in March 2026, drafting of the next version, and a final-text review at ICANN 86 in Seville in June 2026. https://aso.icann.org/rir-governance-document-version-2-status-report-may-2026-now-available/

On 28 July 2026 the ASO AC announced that it had completed version 3 and had "formally delivered this draft to the NRO EC for its consideration and responsibility for the document has now transitioned to the NRO EC." https://aso.icann.org/aso-ac-delivers-recommended-draft-rir-governance-document-to-nro-ec/ The NRO FAQ records the same state of affairs in operative terms: "The ASO AC/NRO NC's drafting mandate is now complete. The Recommended Draft has been delivered to the NRO EC, which is responsible for the next stages, including review, coordination with ICANN and the RIRs, and the pathway toward a final version." https://www.nro.net/policy/internet-coordination-policy-2/faq/ The published timeline places stage 9, "Drafting Final Version of RIR Governance Document," as in process for Q3–Q4 2026, and stage 10, "Approval and Adoption," as upcoming in Q4 2026 with procedures "the NRO EC and ICANN will determine." https://www.nro.net/policy/internet-coordination-policy-2/process-for-the-review-of-icp-2-and-timeline/ The version-3 text published on 1 September 2026 is itself labelled "FINAL DRAFT." https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/

The legal consequence is straightforward: if adopted by ICANN and the RIRs, the Governance Document would supersede and replace ICP-2 — but that adoption has not happened. https://aso.icann.org/icp-2-review/

What version 3 changed — and which criticisms it answered

The rationale report enumerates seven key changes from version 2 to version 3: new or amended definitions (Audit, Compliance Review, Rehabilitation Plan, Temporary Emergency Continuity Arrangement, Temporary Emergency Operator, Transition Plan); a restructured Recognition process with a two-thirds RIR support threshold, conflict-of-interest disclosure and published assessments; clarifications to Service Region, Coordination Limitation and Community Consultation provisions; a revised audit and compliance framework with a five-year regular audit cycle and a distinct Compliance Review process with safeguards against misuse; updated emergency-continuity provisions including an RIR's ability to initiate a Temporary Emergency Continuity Arrangement for its own services, a lowered initiation threshold, a retained 90-day limit; a more detailed Derecognition process that "emphasizes rehabilitation as the preferred path," aligns steps with Recognition, clarifies ICANN's review and decision-making role, requires publication of decisions, and applies a two-thirds RIR support threshold excluding the subject RIR; and amendment safeguards preventing amendment during a Temporary Emergency Continuity Arrangement or while a derecognition proposal is pending. https://aso.icann.org/recommended-draft-rir-governance-document-rationale-report-and-next-steps/

Several of these map directly onto criticisms recorded in the Round 2 Consultation Summary. The change-rationale document records that Article 2.3 was reorganized because "We received feedback that the document was difficult to read as similar issues were covered in multiple articles," and frames the Article 7.2 amendment lock-out as preventing requirements from being watered down "at difficult moments." https://www.nro.net/wp-content/uploads/Draft-v3-Changes-and-Rationale-240826b.pdf The rehabilitation-first derecognition design answers comments that the draft "lacks... intermediate measures between compliance and derecognition" and relied on "subjective terms that may lead to inconsistent application." https://aso.icann.org/icp-2-review/

Which structural objections the draft does not answer

The Round 2 Consultation Summary is notable for what it records and for what it does not. It is explicitly a compilation of attributed community input: "This report does not include the NRO NC's opinions on or responses to the comments submitted." https://aso.icann.org/icp-2-review/ The NRO NC's substantive response is embodied in the version-3 change list, not in any recorded reply instrument addressing each objection.

Four structural objections remain visible in the version-3 text itself. First, on legal force, commenters stated the draft "has no inherent legal force, has a conflict of interest and a transparency problem, and that because the NRO is not a legal body, the draft can only become valid through a contract" — and the NRO FAQ itself notes that "Detailed implementation arrangements are separate from the governance document itself." https://aso.icann.org/icp-2-review/ https://www.nro.net/policy/internet-coordination-policy-2/faq/ Second, on consultation, Article 2.7 of the version-3 text states: "Nothing in this Document either prevents or obliges the RIRs or ICANN to conduct consultations with their respective communities in assessing a Proposal for Recognition or Derecognition" — preserving discretion precisely where commenters asked for guaranteed community involvement. https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/ Third, on amendment, Article 7.1 requires unanimous agreement of ICANN and the RIRs to amend, which protects stability but also means any single RIR can block correction. https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/ Fourth, on transition, Article 7.3 grants a three-year grace period for new obligations after the Document comes into force, and commenters warned that "existing RIRs may agree in principle but fail to comply, undermining accountability." https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/ https://aso.icann.org/icp-2-review/

What to watch in Q4 2026

The operative question for the rest of 2026 is adoption mechanics, not drafting. The NRO NC's recorded next steps after Round 2 were to revise "with consideration to the feedback received through all consultative inputs... before presenting the final draft to initiate the approval and adoption process in late 2026." https://aso.icann.org/icp-2-review/ The NRO EC now owns that process and has stated that "Any further opportunities for community input will be announced by the NRO EC." https://aso.icann.org/recommended-draft-rir-governance-document-rationale-report-and-next-steps/ Until an adoption instrument exists, every recognition, maintenance and derecognition decision in the number-resource system rests on the same 2001 text the process was commissioned to replace.