Summary

  • In a 30 January 2026 letter, APNIC told the Malaysian Communications and Multimedia Commission that it could not process an application for a new National Internet Registry because the former criteria were deprecated and no successor process had been formally adopted.
  • APNIC's strongest reason is consistency: recognising one applicant without current criteria could be unfair, while emerging RIR accountability obligations may require new oversight, compliance and escalation duties for NIRs.
  • The next useful disclosure is not a promise that Malaysia will be approved. It is a public dependency map showing which body controls each gate, what closes it, what record proves completion and how earlier expressions of interest will be treated.

The letter exists. The application procedure does not.

That is the unusual institutional state recorded by APNIC at the start of 2026. Its Executive Council chair, Kenny Huang, wrote to the Malaysian Communications and Multimedia Commission after engagement during 2025 about Malaysia's interest in establishing a National Internet Registry, or NIR. APNIC said it remained committed to considering the requests in good faith. It then said it was not in a position to process an application to recognise any new NIR.

This was not a finding that Malaysia lacked technical capacity, national support or a sustainable operating model. APNIC made no merits assessment in the letter. It said the rulebook under which such an assessment could occur had ceased to be operative. The previous recognition criteria had been deprecated, no formally adopted successor process existed, and opening an application without one would risk inconsistency and unfairness.

That is a serious defence, not a procedural excuse to wave away. A registry should not improvise admission standards for a politically salient applicant and then present the result as neutral precedent. If Malaysia were assessed against one unpublished test and a later economy against another, the absence of a common process would become the substance of the decision.

APNIC also identifies a new upstream constraint. The developing RIR Governance Document contemplates accountability for the conduct of NIRs. If APNIC can be held responsible for an NIR's non-compliance, obligations must be capable of flowing down: oversight, monitoring, escalation, technical integrity, security, financial sustainability and an organisation's full lifecycle cannot be postponed until after recognition.

The difficulty is not that these gates exist. It is that their public state is scattered.

One answer contains several unfinished decisions

The January letter describes an order. First comes finalisation of the RIR Governance Document. Then implementation of its obligations across the RIRs. APNIC expects, after that, to begin a community consultation on comparable NIR standards. That consultation will consider whether the permanent moratorium should be maintained or whether new NIRs should be permitted and, if so, under what criteria. Only then could an application enter a defined process.

By 28 July, the NRO reported that the ASO AC had completed and delivered a Recommended Draft RIR Governance Document to the NRO Executive Council. Responsibility had moved to the NRO EC, which would review the document, coordinate with ICANN and the RIRs and progress a pathway toward a final version. It promised an updated timeline. It did not announce a final document, adoption by the relevant bodies or APNIC implementation.

Those words name distinct states. A recommended draft is not a final instrument. Final text is not adoption. Adoption is not implementation. RIR implementation is not an APNIC NIR consultation. Consultation is not a decision to lift a moratorium. Lifting a moratorium is not adoption of recognition criteria. Criteria are not acceptance of an application, and acceptance is not recognition.

Compressing the chain into “waiting for ICP-2” makes it impossible to see where authority currently rests. Treating every stage as independent makes it equally hard to see the cumulative delay. The smallest accurate representation is a dependency map.

Gate Checked public state Completion evidence needed
Global RIR framework Recommended Draft delivered to NRO EC Authoritative finalisation record and final text
APNIC implementation Not shown complete in the checked sources Effective obligations and APNIC implementation mapping
NIR consultation Expected after finalisation and implementation Call, scope, decision authority, submissions and outcome
Moratorium Permanent since the 2024 EC decision; future reconsideration contemplated A dated, authorised maintain-or-change decision
Recognition criteria Former APNIC-104 criteria deprecated; no successor process in the letter Adopted standards, procedure, review path and effective date
Malaysian request Interest acknowledged; application cannot be processed at this stage Rule-governed acceptance and assessment, with no presumed outcome

This table does not shorten the work. It prevents one unfinished decision from hiding inside another.

“Permanent” is a state, not an eternal fact

In February 2024 the APNIC EC made the 12-year moratorium on new NIR applications permanent. APNIC's announcement said it expected no additional NIRs to be formed. The APNIC-104 page was marked deprecated with immediate effect.

The 2026 letter does not erase that decision. It opens a possible transition away from it. APNIC says the future consultation will consider whether the permanent moratorium should be maintained or whether new NIRs should be allowed. “Permanent” therefore describes the current rule without a scheduled expiry; it does not bind every future competent APNIC body against changing it through a valid process.

There is no contradiction if the transition is explicit. There would be confusion if an applicant were told both that the moratorium is permanent and that a future process may change it, without a public record showing who may make that change and when the question has formally entered decision.

The old criteria illustrate what was lost when APNIC-104 was deprecated. They assigned recognition to the APNIC EC, contemplated publication and public review of applications, and addressed selection, operations, withdrawal and dispute resolution. They may no longer fit current accountability requirements. Their value now is historical: they show that an application once had a named route and decision owner. Deprecation removed obsolete rules, but it also left the entrance state empty until a successor is adopted.

Malaysia has not been given a place in a queue

The letter records MCMC's interest and APNIC's continued dialogue. It welcomes MCMC's future contribution to the consultation. That is meaningful access to discussion. It is not a mandate over the result.

Nothing in the checked evidence says that MCMC would operate a Malaysian NIR. It does not disclose the proposed organisation, membership design, systems, finances or national selection process. It does not show that a complete formal application was submitted. It gives Malaysia neither priority nor a reserved position once a process opens.

This matters because an informal waiting list can become a hidden policy. If earlier correspondents are processed first, the order affects opportunity. If all prior interest expires, years of engagement have no procedural effect. If every economy begins equally on the effective date, APNIC should say so. None of these choices requires revealing confidential correspondence; each requires a rule.

The same discipline applies to participation. MCMC may present evidence and preferences. Other members and regional stakeholders may do the same. The authorised APNIC process must still decide whether new NIRs are permitted and which minimum requirements govern them. A consultation measures input. It does not transfer decision authority to the most persistent participant.

Global obligations need a narrow regional translation

The RIR Governance Document concerns recognition, operation and possible derecognition of RIRs. It is not itself an application form for national registries. APNIC's letter makes the connecting argument: if the RIR is accountable for NIR conduct, some obligations must cascade.

That translation should be narrow enough to preserve regional and national choice. Common requirements can cover accurate registry management, security, policy consistency, auditability, continuity, financial viability, escalation and a lawful end state. They need not dictate which Malaysian institution should operate a service, how domestic stakeholders organise themselves or whether local delivery is preferable to direct APNIC membership.

APNIC's current NIR page describes seven recognised NIRs. They are separate non-profit APNIC Members, not branches run by APNIC. Each economy may have only one, and organisations generally choose between the local NIR and APNIC rather than obtaining resources from both. A new recognition decision would therefore establish a durable operating boundary, not simply add a help desk.

That is why haste would be irresponsible. It is also why an indefinite blank process is costly. An economy considering a national layer cannot plan against criteria that do not exist. APNIC cannot test operational claims under an unpublished standard. Members cannot tell whether the chain is moving or merely accumulating dependencies.

Publish the transitions, not a pre-decided outcome

A useful map would give every gate a stable identifier, controlling body, authority source, entry condition, possible outputs and completion evidence. It would publish a target or review date where one exists and state plainly when none is committed. It would link the final text, adoption record, implementation mapping, consultation, moratorium decision and effective criteria.

For Malaysia and any other previously interested economy, the map should also say whether earlier contact creates no queue position, a notice right, an invitation to resubmit or some other bounded procedural status. Silence should not choose the rule by accident.

This proposal does not ask APNIC to approve Malaysia. A legitimate map must include moratorium maintained and application rejected as possible states. Its purpose is to make authority and order reproducible. A reader should be able to distinguish a gate that is open, one that is awaiting an upstream input, one that has closed without change and one that has produced the rule for the next stage.

APNIC's letter is strongest where it refuses to substitute discretion for missing criteria. The next step is to apply the same discipline to the path that will create those criteria. Good faith is an intention. A dependency map would show the operating state.

Sources