AFRINIC transfer rules: the published CPM and fee notice

Two dates, one rulebook

AFRINIC publishes its Consolidated Policy Manual, currently headed version 1.6. The page itself says ‘Published On 17 November 2020’. Its revision-history table is different: it lists CPM v1.6 under 13 November 2020. That is a page-publication date versus a version date, not a conflict about which version is current. The same revision history records that Section 5.7, ‘IPv4 Resources transfer within the AFRINIC Region’, was added in the 1 July 2017 update.

This matters because the transfer rule is public. The useful question is not whether a rule exists. It is what Section 5.7 permits, what it requires of the parties, and where the published text still leaves judgment to the registry.

What Section 5.7 actually requires

Section 5.7 applies where an organisation has a justified need for IPv4 resources that AFRINIC cannot satisfy. On the source side, the resources must come from an existing AFRINIC member account or a Legacy Resource Holder in the AFRINIC service region. The source must be the current rights holder recognised by AFRINIC and must not be involved in a dispute as to the status of those resources. After approval, the source is barred from receiving further IPv4 allocations or assignments for twelve months.

It also must not have received a transfer, allocation or assignment from AFRINIC in the preceding twelve months, except in merger or acquisition cases.

On the recipient side, AFRINIC must approve the need. The recipient must justify and demonstrate its initial or additional allocation or assignment usage according to policies in force. It must be an AFRINIC member and must sign the Registration Service Agreement for the resources being received. If the transferred resources were legacy resources, they cease to be treated as legacy after transfer.

The transfer section requires usage justification and demonstration. It does not expressly require a business plan. Documentation criteria elsewhere in the manual may require network plans for particular allocation requests, but Section 5.7 should not be paraphrased as a general business-case approval.

The fee page is a separate instrument

The Fees & Payment page is not the CPM. It says the fee schedule is ‘as of 2008 unless otherwise amended’ and supplies no amendment history. For transfers between two existing Resource Members, AFRINIC says it ‘does not charge any fees for IP and ASN resource transfers at the moment’. The recipient’s category is recalculated after the transfer, and a new fee may apply at the next renewal. Both accounts must be in good standing before Registration Services considers the transfer.

A new-organisation recipient is treated differently. It must apply for AFRINIC membership and resources. The fee equals the allocation fee applicable to the approved resources plus the membership fee for the recipient’s category. The organisation’s handle changes. Any transfer must comply with the transfer policy or guideline in force at the time.

‘At the moment’ is a date marker. It describes the position when the page was written. It does not establish an earlier fee treatment and does not promise a future one.

Where the 45-day rule belongs

The IPv4 Exhaustion page says AFRINIC announced Phase 1 on 31 March 2017 and entered Soft Landing Phase 2 on 13 January 2020. The current page labels the current phase as Phase 2. In Phase 2, the minimum allocation or assignment is /24 and the maximum is /22; the evaluation criteria also require efficient use of at least 90% of previously delegated space for additional blocks.

The 45-day reservation and the new-member Registration Service Agreement deadline appear in the page’s Phase 1 request-handling text. That text says an approved prefix is reserved for up to 45 days pending payment, and that a new membership applicant must also send the signed agreement within the same 45 days. The Phase 2 section states the /24-to-/22 limits and evaluation criteria, but it does not repeat the 45-day deadline. This article therefore attributes that deadline to Phase 1 request handling, not to Phase 2.

What remains outside the published text

The CPM establishes conditions; it does not publish a transfer-processing record. The term ‘dispute as to the status’ is not defined in Section 5.7. Recipient need review remains a judgment about documented usage. The fee page is a service notice with a date reference, not a dated tariff history.

The captured NRO statistics page lists daily extended allocation and assignment reports, daily RPKI adoption reports, quarterly Internet Number Status Reports published since 2005, and RIR regional statistics. It does not show transfer throughput, processing time or refusal reasons. That absence is not evidence of misconduct; it is a limit on what the statistical programme lets a reader verify.

Conclusion

The transfer conditions are published. AFRINIC’s CPM and fee page together show a need-based rule, a qualified no-charge position for transfers between two existing Resource Members, and a separate fee path for a new-organisation recipient. The remaining issue is administrative: whether the registry applies those published conditions consistently and explains its decisions clearly enough for counterparties to rely on them.