Summary

  • AFRINIC’s Board ratified the Number Resources Transfer Policy on 4 February 2026. AFRINIC’s own summary states the rule: “AFRINIC-issued IPv4 cannot be transferred out of the region”. Only legacy resources and resources that were transferred in from elsewhere may leave.
  • The staff assessment published with the proposal gives the reason in financial terms: “AFRINIC will not lose its current resource members to other RIRs in outgoing transfers.” The legal assessment calls the choice “purely and simply a business decision”.
  • Cloud Innovation’s page on the policy calls it a door that only opens inwards. Its position, and Lu Heng’s, is that the freedom to leave is what keeps a registry honest.

What was ratified

The policy carries the reference AFPUB-2020-GEN-006-DRAFT03. The proposal was first submitted in October 2020; AFRINIC’s staff assessed it on 28 February 2022; the Board ratified its third draft on 4 February 2026. AFRINIC’s summary says it now governs transfers of IPv4 addresses and autonomous system numbers between AFRINIC members, from legacy holders to members, and between AFRINIC and other regions “provided reciprocal policies exist”.

It works by sorting every resource into a category. Addresses from AFRINIC’s own pool are “Regional”. Special-purpose blocks are “Reserved”. Legacy space is “Legacy”. Space that arrived from another region is “Global”. The staff assessment adds a detail operators should note: the categories “are for resource policy administrative purposes and shall not reflect in the WHOIS”. A network cannot look up which side of the fence its own addresses are on.

The rule in one line

The proposal states it without decoration: “Only Legacy resources and resources transferred in from other regions will be transferable out of the AFRINIC service region.”

Inward transfers are another matter. The staff assessment summarises the rule for them as permitting “any”, so long as the source registry’s policies are met. So an operator in Nairobi or Dakar may bring addresses in from Europe or North America. It may not take the addresses AFRINIC issued to it anywhere else, whatever happens to its business, its customers or its confidence in its registry.

Nothing moves without AFRINIC’s signature either. Under the policy, “Number resources are non-transferable unless AFRINIC has expressly and in writing approved a request for transfer”, and AFRINIC “is tasked with making prudent decisions on whether to approve”. Resources transferred without its prior approval, the staff assessment says, “shall be reclaimed”.

Why: AFRINIC’s own words

The proposal’s own problem statement sets the aim: to let unused IPv4 from other regions move into AFRINIC’s service region “without necessarily depleting AFRINIC’s slim amount of IPv4 addresses by transferring space out of the region”.

The staff’s financial assessment is two sentences long and worth reading in full: “Since IPv4 & ASN resources from the AFRINIC Pool can only be transferred in-region(Intra), AFRINIC will not lose its current resource members to other RIRs in outgoing transfers. This proposal will therefore have a minimal financial impact on AFRINIC’s revenue.”

The legal assessment is just as direct. Whether to allow inter-regional transfers “is not strictly a legal one. In fact, it is purely and simply a business decision”, to be taken by directors acting “in the best interests of the company”. It then defines those interests: “considering the real financial impact of such policy for AFRINIC so that the sustainability and business continuity of AFRINIC, both as a company and RIR, is not compromised.”

There it is, in the registry’s own file. The measure of the policy was what it would do to AFRINIC’s income, and the answer that satisfied its staff was that members could not leave. Cloud Innovation’s reading needs no embellishment: “That is a registry counting its members as stock it does not intend to lose.”

What AFRINIC tells its members instead

The summary page presents the same policy to members in a different register. It says the policy “Enables Controlled and Transparent IPv4 Redistribution” and the policy “Strengthens AFRINIC’s governance mandate in managing Internet number resources within the African region”. A question-and-answer section asks whether the policy confiscates members’ IPv4 and answers no: “Members retain their rights of use”. Asked whether the policy reduces the value of members’ addresses, AFRINIC replies that it “does not assign monetary value to number resources”.

Rights of use are the phrase to watch. AFRINIC’s Registration Service Agreement gives a member “an exclusive right of use” and has it acknowledge that the resources “are not property”. A policy that leaves a network the use of its addresses and removes its ability to take them elsewhere fits that contract exactly. And a registry that measured the policy by its own revenue is poorly placed to tell members that money has nothing to do with it.

As for the “governance mandate”: Cloud Innovation’s answer is that no law gives a private registry one. A registry exists to keep an accurate record of who holds which addresses: “recording a transfer is its job, and forbidding one is not.”

A warning from AFRINIC’s own lawyers

The policy requires anyone receiving addresses to sign the Registration Service Agreement, and legacy space that is transferred in “will no longer be considered legacy”. AFRINIC’s legal assessment saw where that leads. It asks whether AFRINIC will be able to apply its agreement to such transfers “with the obvious risk of the concerned IP number resources being reclaimed by AFRINIC in case of a subsequent breach of the RSA, despite that the recipient organisation would have most probably paid good consideration (financial value) for such transfers.”

AFRINIC’s lawyers, in other words, described a buyer who pays for addresses, brings them into the region and can then lose them to the registry. The one-way door has a second lock on the inside.

The assessment also records that the door is not matched on the other side. The staff found the proposal “not reciprocal with ARIN, as ARIN does not have a restriction on outgoing Inter-RIR transfers”, and LACNIC’s compatibility “yet to be confirmed”.

Why the exit matters

The single registry per region was a convenience. RFC 1366 asked for it in 1992 “to provide for efficient and fair sub-allocation of the address space”. A convenience that cannot be left becomes something else, and Lu Heng’s Bill of Rights of Uniqueness Coordination names it: “Without portability, coordination becomes lock-in. Without exit, service becomes power.”

His Note 78, published on 13 November, puts the obligation where it belongs: “If you are the only provider in town, the conclusion should run the other way. You owe more, not less.” A provider that locks the door, he writes, “is protecting itself from its customers”.

Cloud Innovation asks for every member what the customer of any service has: the right to change provider and keep what is theirs. Its pages “Own your IP” and “IP for Africa. Not Africa for AFRINIC.” set out the alternative: addresses that are securely the network’s, that it may use, transfer and take to another registry. “A registry that cannot lose its members has no reason to serve them.”

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