Summary

  • Draft 2 preserves the 90% baseline while proposing a waiver for demonstrated key technical purposes.
  • A waiver packet should show topology, need, alternatives, utilisation and fraud controls without presuming that any member qualifies.
  • Rough consensus at AFRINIC 37 and the current Last call label are different from Board ratification and implementation.

Publication note: Published is the scheduled editorial date, 7 September 2026. The actual server publication time is unset.

Current CPM section 5.4.6.1 requires an LIR or End User seeking another IPv4 allocation or assignment during the Exhaustion Phase to have used at least 90% of all previous allocations or assignments. A new LIR or End User with no prior resources receives a first-request exception.

AFPUB-2026-IPv4-002-DRAFT02, dated 16 June 2026 after draft 1 on 6 May, would retain that baseline. It proposes treating a qualifying request as a first request where AFRINIC verifies a demonstrated key technical purpose that is not practically serviceable from the operator’s existing pool, or that creates technical constraints for that pool. Its non-exhaustive examples are redundancy and high availability, IPv6 transition mechanisms, and expansion to new sites.

The justification must be sufficiently documented for compliance verification, but the draft does not specify a public evidence schema, minimum document set, case decision record or publication rule.

That omission matters because “key technical purposes” can otherwise absorb ordinary operational preference. The proposal author’s examples—data-centre expansion and an ISP with multiple BGP points of presence using 464XLAT and NAT64—illustrate the policy case; they are not verified evidence about a particular member. The author also attributes the absence of immediate pool-drain risk to roughly three million recovered IPv4 addresses. That is an attributed policy argument, not an independently measured inventory fact here.

AFRINIC staff describe the 90% threshold as the baseline and say an override should be limited to technical, not operational, constraints. Staff expect hostmasters to receive a documented policy, while warning that procedures must identify fraudulent requests and prevent abusive use. They say Member Services procedures and FAQs would need updates, with no identified changes to WHOIS, RDAP, MyAFRINIC, NetSuite, NMRP or RPKI. Staff report no overlap with other proposals and assess that implementation could fit the CPM timeline, with a target of within 30 days of ratification.

That remains an assessment and plan, not evidence of ratification or implementation.

At the 24 June 2026 AFRINIC 37 Public Policy Meeting, discussion covered the difficulty of reaching 90% across multiple sites and the difference between efficient use and operational topology. The formal chair decision recorded rough consensus and said the Secretariat would share a definition of utilisation during Last Call. An open-microphone exchange briefly recorded a participant saying the proposal had not passed before the PDWG co-chair clarified that it had reached rough consensus. The formal decision is controlling, but the corrected moment shows why decision receipts matter. At the reporting freeze, AFRINIC’s current-proposals page labels the proposal Last call. Last Call is community review; the PDP still separates it from a later Board recommendation, Board ratification and implementation.

BTW analysis: proposed evidence packet. A repeatable case file should identify topology, sites and service roles; explain the requested prefix size; calculate current and projected utilisation; compare alternatives; define the time-bounded need; record fraud checks; name the reviewer; and state the decision date, conditions and later review point. Evidence should connect each claimed constraint to an operationally necessary function, not merely to convenience or preferred architecture. A decision receipt should record the rule applied, material evidence, reasons for acceptance or refusal, conditions and review date. This is a BTW recommendation, not an AFRINIC product or adopted requirement.