What Electricity Regulators Know About Essential Network Records

Summary

• Modern electricity regulation offers three precise lessons for number registries: define service outputs and remedies, expose efficient costs and cross-subsidies, and constrain disconnection through notice, remedy, suspension of claims, restoration and continuity provisions.
• These lessons concern dependence around a record, not the physical nature of electricity. IP addresses are not consumed energy, registry databases do not carry packets, and Regional Internet Registries do not own territorially exclusive wires or balance supply and demand in real time.
• Ofgem's guaranteed standards and Australian reliability incentives show why availability, transaction time, correction time, duration of stale states and repeated incidents need separate measures. Copying electricity interruption indices without defining registry function would create false precision.
• Current ARIN, RIPE NCC and APNIC documents show that non-payment can lead, via service suspension or termination, to directory removal, deregistration, certificate consequences or revocation. The appropriate analogy is procedural protection calibrated to operational dependence, not permanent immunity from action.
• Cost-of-service review should make the narrow registry service, reserves and adjacent activities audible. It should not create a guaranteed return on a digital rate base, a global public utility commission, state ownership or broad regulatory control over operators.

The comparison begins by refusing equivalence

An electricity connection and an Internet number record can both become essential for an organisation that depends on them. That is the reason to compare their institutions. It is not a reason to say they are the same thing.

Electricity is generated, transported over physical systems, balanced continuously and consumed. Distribution networks have geographic service areas, high sunk capital and local natural monopoly characteristics. A household cannot generally ask another set of wires to reach the same premises tomorrow. These conditions support public regulation of tariffs, investment, quality and disconnection.

An IP address or Autonomous System number is an identifier used by networks. A registry maintains allocation and registration state so that globally unique numbers are not assigned to more than one party at the same time.RFC 7020expressly places the decision whether and how addresses are announced outside the Internet numbers registry system. Databases do not carry packets, and a registration entry is not a unit of connectivity delivered every second.

The comparison is therefore institutional and procedural. Both contexts can contain a narrow service on which others depend, an information asymmetry between the administrator and the user, difficult exit, costs recovered over a captive base, and adverse actions with consequences larger than the unpaid bill or the incorrect field that triggered them.

The useful comparison starts by identifying this dependence. The wrong comparison starts by equating the entire state of electricity because the word 'essential' appears in both descriptions.

Electricity regulation since the 1990s is not a single command model

The modern electricity record does not support a simple claim that essential networks must be state-owned and centrally directed. Since the 1990s, major reforms have often tried to separate monopoly network functions from activities where competition is possible.

In the United States, the Federal Energy Regulatory Commission's Order No. 888 required covered electric utilities to file open, non-discriminatory transmission tariffs with minimum conditions. It aimed to limit the use of transmission control to disadvantage competing electricity sellers. It did not nationalise all transmission assets.

The European Electricity Directive of1996started an internal market framework that separated generation, transmission and distribution functions. The currentDirective (EU) 2019/944continues rules on unbundling, network independence, non-discrimination, market access and consumer protection. It accommodates both public and private ownership while constraining conflicts around network control.

Britain's RIIO price controls and Australia's service incentives add performance-based techniques to traditional cost review. The lesson is plural: specify the indispensable function, constrain monopoly leverage, measure outcomes and allow competition where the common network does not require exclusivity.

For registries, this points to a thinner common record and a more replaceable service, not a ministry of Internet numbers.

A functional map shows which parts can travel

The two systems can be placed side by side without collapsing into each other.

The last line is decisive. Competing electricity distributors cannot generally use separate wires to provide indistinguishable service to the same premises. Competing registration providers can, in principle, serve portable records if a common uniqueness rule, verifiable succession and interoperability of dependent systems prevent double registration.

The coordination fact does not prove that one institution must remain the permanent service monopoly.

Guaranteed standards turn service language into obligation

Britain's guaranteed standards of service require electricity distribution companies to meet specified service levels. Covered failures can trigger payments to customers, subject to exemptions. The standards address issues such as restoration, connections and voltage quality. Ofgem describes the payments as compensation for inconvenience, not full compensation for consequential financial loss.

This distinction is useful for registries. A promise to provide 'high quality service' gives little for an operator to test. A guaranteed standard names the function, the clock, the stopping conditions, the evidence, the exception and the remedy. Registry commitments could cover acknowledgement of an authenticated request, initial review, correction of a proven data error, restoration of access, completion of a portable export, incident notice and publication of a post-incident account.

The remedy need not claim to cover every commercial loss. A fixed service credit, a fee refund, a funded independent review or other limited payment can create an institutional consequence without requiring the registry to price every downstream dependence. More serious losses may remain subject to contract and applicable law.

Exceptions require evidence. A registry should not stop the clock simply by asking a repetitive question or classifying every security event as exceptional. Similarly, a user should not receive automatic compensation for a delay caused by missing authentication or a judicial restraint.

The transferable principle is administrability: the user can tell whether the provider performed and what follows if it did not.

A single availability number hides the service that failed

Electricity regulators have learned to separate aspects of reliability. The Australian Energy Regulator's distribution service incentive work uses standardised interruption concepts and indicators such as System Average Interruption Duration Index and System Average Interruption Frequency Index. The purpose is not just to report whether a company was generally available. Duration, frequency, repeated events and customer exposure can produce different pictures.

A registry needs the same decomposition but not the same formula. Public RDAP may remain available while authenticated updates fail. A portal may work while certificate publication is stale. A database may answer every query quickly and return an incorrect holder. A transfer may complete administratively while a dependent service lags. A single percentage cannot describe these failures.

The service account must distinguish read availability, write availability, authentication, registration accuracy, correction latency, transfer latency, export completeness, certificate and repository status, and incident communication. It must publish the number and duration of stale or conflicting states and the recurrence of errors after correction.

External measurement is important. A provider that measures only the front door may miss failures seen by operators in other regions. Sampling requires clear denominators and treatment of planned maintenance. Serious incidents must not disappear in annual averages.

Electricity indices teach the need for consistent units and comparable definitions. Copying SAIDI or customer-minutes directly would only replace vague claims with inappropriate arithmetic.

Accuracy deserves its own service level

The utility analogy is strongest when it goes beyond availability. Voltage can be present and still outside required quality. Registry data can be online and still incorrect.

RFC 7020 calls registration accuracy a fundamental requirement because unique numbers need correct allocation information for operational purposes. A registry service standard should therefore define more than response time. It should measure accuracy of sampled fields, completeness of provenance, age of unverified contacts, time between a supported correction request and the changed state, notification time to dependent systems, and the proportion of corrections later reversed.

Different fields need different clocks. A compromised account or conflicting proof of control may need immediate hold. A corporate successor request may need document review. A routine contact update may be faster. The standard should publish categories rather than let every request enter an unbounded queue.

An accuracy remedy should fix the state and its consequences. The provider may need to restore access, republish corrected data, notify dependent services, reverse a fee, retain the prior record and explain why the error occurred. A credit without correction is not a remedy; a silent correction without provenance makes subsequent disputes harder.

This is an area where current registry practice could exceed electricity regulation. Digital state is easier to version and compare than a physical blackout. The audit trail can show exact transition time and authority if institutions are designed to do so.

Cost of service is a question before it is a pricing formula

The US Department of Energy's Electricity Distribution System Baseline Report describes the traditional regulatory compact: a monopoly franchise and obligation to serve in exchange for oversight, recovery of prudent service costs and an opportunity to earn a fair return on capital. Regulators determine a revenue requirement and allocate costs between services and customer classes.

The most useful lesson for the registry comes before the return calculation. How much does the essential service cost? What activities are necessary for uniqueness, accurate registration, security, continuity and portable access? What costs come from education, research, advocacy, conferences, policy development or adjacent technical products? Who benefits and who pays?

An activity budget can answer these questions only if the categories are stable and the allocation methods visible. Staff serving multiple functions need a reasonable allocation basis. Shared infrastructure needs disclosed treatment. Reserves need a purpose linked to continuity risk. Capital and operating costs must not be shifted between categories simply to defend a fee proposal.

Cost review does not determine legitimate scope. An institution could perfectly account for an activity it should not compel all users to fund. The narrow mandate must come first; accounting then tests whether fees efficiently support it.

This is the transferable heart of cost-of-service regulation: making captive payment answerable to the service that justifies the captivity.

The utility fair-return bargain does not default to a registry

Electric networks require substations, lines, transformers, control equipment, maintenance and long-term investment. Traditional rate regulation gives an investor-owned utility the opportunity to recover prudent costs and earn a reasonable return on capital devoted to the utility service. This bargain supports financing where customers cannot discipline the provider through ordinary competition.

A number registry has real costs: secure systems, skilled staff, authentication, databases, certificate services, legal work, audits, incident response and reserves. It does not follow that every expense should enter a digital rate base earning a guaranteed return. The incumbent may be a non-profit association. Much of the value may be software, data, contracts and trust rather than irreversible territorial plant.

Creating a utility-style return could reward institutional expansion. More staff, property or proprietary systems could increase the base from which fees are justified. It could also entrench the provider by treating replaceability as a threat to approved investment.

Registry finance should rather start with efficient service cost, open interfaces, independent procurement, reserve needs and tested continuity expenses. If a commercial provider participates, its profit should face competition and contractual choice whenever possible. The common uniqueness layer should not guarantee a return simply because its records are essential.

Electricity regulation teaches why a fair return exists. That explanation is also the reason not to extend it when physical capital and franchise conditions are absent.

The RIPE NCC budget illustrates both transparency and the next question

RIPE NCC's Activity Plan and Budget 2026 reports a revenue and expense budget of €41.1 million, an expected 20,000 LIR accounts and activity-level descriptions. The 2026 Charging Scheme sets annual fees per LIR account and additional fees for specified services and resource categories.

The publication is materially better than an unexplained invoice. Members can see planned staff, operating costs, activities and reserves. They can debate a charging scheme and review audited results.

The utility comparison raises an additional question: how much of the total supports the narrow essential registration and how much supports other institutional choices? A simple division of the budget by LIR accounts would be misleading. Accounts impose different demands. Some activities serve the wider Internet. Reserves protect future continuity. Cost causation and benefits are not identical.

A stronger account would identify incremental and shared costs of registration, authenticated modifications, transfer processing, RDAP, database integrity, RPKI, incident restoration, portability, governance, external contributions and education. It would publish allocation rules and volume sensitivity. Members could then see whether fixed fees, resource-based fees, transaction fees or a general contribution matches the service.

This is not a conclusion that the current budget is excessive or justified. It is a method to convert transparency on totals into accountability for scope and cross-subsidy.

Ring-fencing is more transferable than ownership

Electricity reform often separates control of the common network from generation and supply. The purpose is not aesthetic corporate neatness. A company controlling an essential access could otherwise use network information, pricing or delay to favour its competing affiliate.

The Australian Energy Regulator's Ring-fencing Guideline for Electricity Distribution deals with functional separation, compliance reporting and executive accountability. EU rules likewise require that transmission and distribution functions be independent of competing generation or supply interests under defined circumstances.

A registry can also exercise adjacent activities: brokering, consulting, certification products, training, conferences, policy advocacy, research or commercial data services. The risk is not that every combination is improper. It is that control of the essential registration can confer non-public information, captive customer access, cost recovery or discretionary leverage on the adjacent activity.

Transferable controls include separate accounts, role-based data access, published conditions, conflict declarations, executive attestation, non-discrimination testing and independent audit. A registry should not delay a transfer because a customer refused its affiliate's service, or fund a contestable product through unavoidable registry fees without disclosure.

Corporate separation is one tool, not an automatic answer. A small service may achieve the same protection through functional controls and open interfaces. The electricity lesson is to regulate the conflict created by the bottleneck, not to require public ownership of everything nearby.

Open access means comparable service, not unlimited right

FERC Order 888 made comparability central to transmission access. A utility should not offer itself better terms for the same network service than it offers others. This principle transfers cleanly to number administration.

Comparable registry service means published eligibility conditions, evidence requirements, queues, fees, interfaces, reasons and review. Operators in similar circumstances should not receive different treatment because one is an institutional insider, a conference sponsor, a policy entity, a broker customer or a critic. Automated and manual paths should be documented, and expedited service should have transparent criteria and price.

Open access does not mean every request must be approved. A transfer may fail authentication. A correction may lack evidence. A resource request may be outside current policy. Security restrictions and privacy checks may be needed. The obligation is to apply defined conditions consistently and provide an accountable reason.

It also does not mean unlimited public access to sensitive records. The common service can offer public operational fields, authenticated holder access and protected evidence review under different conditions. Comparability applies within the class.

The open access history in electricity shows that publishing a tariff is not enough if the incumbent controls capacity calculations, information and implementation. Registry comparability likewise needs outcome data: processing times, further evidence requests, approval, denial, appeal and reversal by request class. Otherwise a neutral rule can coexist with discriminatory administration.

Disconnection is a sequence, not a single switch

Electricity law distinguishes planned interruption, safety disconnection, non-payment, supplier failure and emergency action. Notice, restoration and protection vary by trigger. Registry discussions often compress an equally varied sequence into the single word 'revocation.'

The actual acts may include suspension of portal access, service suspension, removal of data from public directory, rejection of updates, termination of RPKI service, revocation of certificates, deregistration of records, termination of an agreement, recovery of resources and their reissuance. Each has a different mechanism and reversibility. Some may quickly affect dependent systems; others may leave routing behaviour unchanged until operators act.

A regulatory analysis should map each step, trigger, clock, notice, responsible officer, evidence, review, restoration condition and downstream dependence. It should ask whether a less disruptive step can secure payment or integrity before a more destructive one. It should distinguish the technical act of the registry from an operator's routing decision.

The term 'disconnection protection' is therefore comparative. It does not claim that a database action is identical to cutting a home's power. It asks the same administrative question: when an institution controls an essential service relationship, what procedures should precede an avoidable loss of continuity?

Precision reduces both alarm and complacency. The public can see which consequence is real rather than treating every overdue account as an immediate Internet outage or every registry notice as harmless paper.

The precise sequence of non-payment is a concrete test case

ARIN's current page on revocation, return and restoration of resources describes a staged sequence for resources covered by a Registration Services Agreement. At 120 days after the invoice due date, ARIN says it stops services and removes associated resources and records from public Whois and RDAP. At 180 days, it may terminate the agreement, revoke resources and return them to inventory. Restoration is possible under stated conditions before reissuance.

The procedure has features that electricity regulators would recognise: bills, repeated deadlines, a service suspension step, a later termination step and a restoration path. The analogy also reveals unresolved design questions.

Does the final notice reach more than one operational contact? Can an organisation challenge a billing or identity error without the contested ground advancing toward revocation? Which services stop together at day 120, and why? What evidence proves public directory removal and restoration? How are networks, critical customers and counterparties warned before a potential reissuance? What independent review exists when the holder contests the ground rather than simply needing more time to pay?

These questions do not prove that ARIN's rule is invalid. They show how a published sequence can be assessed for notice, proportionality, reversibility, continuity and remedy. The same method should be applied to every registry rather than treating one region's timeline as a universal standard.

RIPE NCC's closure document shows why the affected service must be named

RIPE NCC's document on closure of members, deregistration of Internet resources and legacy resources describes several grounds and procedures for terminating a service agreement. Its consequences may include loss of portal access, digital resource services, authority to hold records, RPKI service, deregistration and revocation of certificates generated by the certification service.

This list is important because 'membership termination' sounds corporate while the service consequences are operational. A member may lose voting rights and training access at the same time as registration and certification state changes. A notice can therefore bundle association, payment, identity, database and security effects.

Electricity regulation would ask whether each bundled consequence is necessary for the trigger. A payment default may justify collection and eventual service limits. It does not automatically explain the timing of certificate revocation or the safe handling of records on which third parties rely. False documents or a court order present different risks and may justify different immediate measures.

A better public timetable would list each effect separately with its justification, clock, dependency, suspension rule and restoration method. Operators could plan continuity, reviewers could assess proportionality and the institution could demonstrate that it did not use the most consequential lever simply because it was administratively available.

The public service lesson is not to never terminate. It is to never hide a cascade of essential service consequences in a single corporate verb.

APNIC's reactivation period exposes the importance of finality

APNIC's fee schedule states that non-payment leads to termination, allows reactivation within three months subject to a fee, and states that resources may then be deregistered and returned for reallocation if the account is not reactivated. The membership agreement places this in a contractual service relationship.

The existence of a reactivation period is a continuity protection. It recognises that termination need not become immediately irreversible. The difficult question is the limit after which a later applicant can rely on finality.

Before reallocation, the registry should be able to prove notice, authority, expiration of remedy and review, final status of dependent services and absence of a pending good-faith dispute. The former holder needs to know which act remains reversible. A recipient needs assurance that the resource is not subject to a hidden claim. Operators need sufficient public status to avoid conflicting reliance.

Electric restoration generally returns service to the same connection. Number reissuance can create a new party with competing reliance, making reversal much harder. This difference argues for a stronger process before finality, not permanent reservation after every default.

The key transfer is staged irreversibility. Early steps should be easy to remedy. Final reallocation should occur only after the evidence and review record can support third-party reliance.

A claim suspension should be narrow, real and non-punitive

The consolidated EU Electricity Directive protects vulnerable customers and customers affected by energy poverty from disconnection and includes safeguards when the ground is subject to a claim or alternative dispute resolution. The exact household protections do not transfer to entities holding digital resources. The procedural insight, yes.

An operator that timely contests the factual or contractual ground of an adverse registry act should be able to obtain a limited suspension before irreversible change. The suspension should apply to the contested ground, preserve the last uncontested state as far as possible, and continue only while the operator meets deadlines and does not create an independent security risk.

The institution needs protection against tactical delay. A claim should identify the contested fact, the remedy sought and supporting evidence. A reviewer should be able to dismiss repetitiveness or require security for uncontested fees. Emergency action may remain available for compromised credentials, conflicting control or a valid court order, with swift independent review.

Filing a claim should not by itself trigger a worse service class, a public suspicion mark or loss of unrelated functions. That is what non-punitive means. The operator retains essential continuity while the institution determines whether its ground is correct.

Suspension becomes real only if the reviewer has the power to halt execution. A suggestion box that cannot stop deregistration is not the analogue of protected service; it is post-hoc documentation.

A successor provider is useful; a duplicated truth is not

Electricity law uses supplier of last resort and continuity arrangements when a retail supplier defaults. The current EU framework requires continuity for protected classes under defined conditions. A number registry analogue would be a qualified successor service capable of preserving essential records and identifiers when a provider defaults.

The analogy stops at the uniqueness boundary. Two electricity suppliers can account for energy delivered over the same physical network on successive periods. Two registries cannot publish conflicting authoritative holders for the same resource to the same dependent set without undermining coordination.

Succession therefore requires a portable state format, authenticated transition, complete history, protected evidence transfer, conflict verification, identification plan, public failover and rollback rule. The successor should not need the defaulting institution's discretionary approval if pre-agreed technical and legal triggers are met. An independent escrow agent may hold encrypted recovery material and activate it only under defined conditions.

Regular exercises should prove the arrangement. A paper promise by two institutions under common control is weak evidence. An independently operated successor should test state, answer queries, process an authorised update and deliver service without duplicate authority.

The electricity idea worth keeping is that supplier failure should not become customer failure. The mechanism must be rebuilt for a globally unique informational record rather than copied from retail supplier switching.

Universal electricity service does not imply universal IPv4 allocation

Article 27 of the EU Electricity Directive describes a territorial right of households, and in some cases small enterprises, to electricity of specified quality at transparent, non-discriminatory prices. This answers electricity's role in ordinary life and a network capable of connecting premises under regulated conditions.

There is no equivalent promise that every person or enterprise must receive scarce IPv4 resources from a registry. The remaining allocation pool, historical distribution, technical alternatives and operational needs are different. An obligation to maintain accurate records for existing relationships does not create an unlimited right to a finite block of identifiers.

The distinction prevents the utility analogy from becoming a new allocation mandate. Registry access should be non-discriminatory within published service classes. Requests should receive reasons and review. Existing holders should receive accurate and portable service. None requires pretending that every requested resource can be supplied.

The availability of IPv6 does not dissolve the problem either. It is a different identifier space, and many networks operate both protocols. The regulator's lesson is to define the service entity before promising universality.

The public interest case is stronger when it is narrower: anyone who depends on a recognised number record should receive fair administration of that record, and anyone seeking service should face transparent criteria. That is an administrative right. It is not a claim on an unlimited physical supply.

Territorial regulation is the wrong geometry for a global registry

Electricity distribution regulation is territorial because wires, franchises, safety authorities, consumers and courts are located. Even interconnected wholesale markets remain organised across legal jurisdictions and physical control areas.

Internet number records coordinate networks that cross borders, serve customers in many countries and announce routes globally. The current RIR structure is regional, but the uniqueness requirement is global. A record made valid only within a state's borders would not solve duplicate use for networks elsewhere.

A country can regulate companies, contracts, data, security and conduct within its jurisdiction. A court can order a registry or an operator subject to it to act. These public powers are real. They do not turn the global digital space into national electricity franchises without technical and legal consequences.

Copying territorial utility command could produce multiple state-authorized claims on the same block, barriers to provider portability and policy conditions unrelated to uniqueness. Operators would then face a choice between inconsistent official records, while routing continues through autonomous decisions.

The best transfer is procedural. National law can require due process, consumer or business protection, audit, competition and remedy from actors in reach. International and private arrangements can preserve interoperable uniqueness. Neither level needs to claim the other's geometry.

Electricity regulation works partly because the regulator's territory matches the network service. Number governance must admit where this premise fails.

State ownership is neither required by electricity nor suited to registration

Electricity systems include state-owned enterprises, municipal utilities, cooperatives and investor-owned companies. Modern regulatory rules often apply non-discrimination, service and separation duties across ownership forms. The EU framework expressly recognises public and private structures while focusing on effective independence and conflicts.

Ownership alone does not produce accurate records, fair procedure or continuity. A public registry can be politicised, underfunded or slow. A private non-profit can be transparent and technically strong while exercising unreviewable leverage. A commercial provider may innovate while creating incentives to overcharge or lock in users. Institutional tests should follow function.

For essential number records, public authorities can set legal limits and enforce rights without owning the service. Operators can choose among qualified providers if portability and consistent uniqueness state are preserved. Independent review, audits, open protocols, reserve requirements and succession can constrain private administration.

State ownership may be appropriate in a particular jurisdiction for a particular public service. It is not a global answer to transnational identifier coordination. Which state would own the registration, and what authority would its decision have over operators and courts elsewhere?

Electricity diversity provides the caution. The lesson is not public versus private. It is to match authority, incentives, service obligations and remedy to the function that creates dependence.

A heavy public service cast would thicken the registry in the wrong places

Electricity regulators approve investments, security plans, tariffs, connection rules, reliability standards and sometimes resource planning because physical networks, environmental effects and real-time balancing create broad public consequences. The same magnitude in number registration would invite control over operator business models, routing, leasing, customer geography, financing and network design.

Most of these choices need not be common for uniqueness. A registry can verify a consistent holder relationship without deciding how the holder finances a resource or what legitimate customers it serves. It can publish a route origin identification service without ordering each network's routing policy. It can preserve contactability without becoming an abuse tribunal for the entire Internet.

A heavy cast also increases capture risk. An incumbent registry with captive customers and wide policy power can make its own institutional preferences part of the service. A state regulator can then add political priorities. The common layer becomes a vehicle for every problem that lacks another practical lever.

The electricity analogy should instead target narrowly. Regulate the bottleneck behaviour: accuracy, access, service quality, cost allocation, non-discrimination, adverse action, review, portability and continuity. Leave contestable and local choices outside unless evidence shows they threaten a defined common invariant.

A thin registry can be strongly accountable. Thickness and accountability are not the same thing.

RPKI demonstrates why consequence must be traced, not presumed

Registry action can affect more than a directory. In RIPE NCC's closure document, termination can end hosted certification service and revoke certificates generated by that service. Other RIRs have their own conditions and architectures. These facts make continuity safeguards important, but they do not prove that every adverse registry act disconnects traffic.

RFC 6480 describes the architecture of certificates and signed entities. Relying party software retrieves and validates data; operators choose how validation results affect routing policy. A certificate event, repository event, validator observation and router decision occur at different points.

An electricity blackout metric can observe whether supply reached the premises. A registry incident account needs a chain. Which record or certificate changed? When was it published? Which validators observed the state? Which routes became valid, invalid or not found? Which networks applied rejection or preference? What customer effect followed?

This chain prevents both understatement and exaggeration. A registry cannot dismiss a certificate revocation as mere administration. A critic cannot attribute every route change to the registry without operator evidence.

Service commitments should attach to the provider's own act: notice, correct authorisation, repository availability, rollback and restoration. Broader harm claims need downstream measurement. Electricity regulation teaches service quality accountability; Internet architecture teaches where that service stops.

A registry service covenant can capture the useful lessons

The transferable disciplines can be assembled without declaring a public utility. A registry service covenant would state a narrow purpose, measurable outcomes, cost rules, adverse action protections, portability and oversight.

It would define service schedule: availability and transaction classes, accuracy measures, correction and restoration clocks, incident communication, export completeness and automatic remedies. Its cost schedule would identify essential activities, shared costs, reserves, adjacent services, allocation methods and fee objectives. Its rights schedule would provide notice, reasons, evidence access, remedy, claim suspensions, independent review, restoration and limited compensation.

Its continuity schedule would name backup contacts, protected dependencies, identity management, escrow, successor providers, failover and duplicate prevention. Its competition schedule would require open interfaces, non-discrimination, conflict controls and separation of unavoidable fees from contestable services. Its oversight map would identify auditors, reviewers, public authorities, courts and remedies.

The covenant would also contain express exclusions. It would not grant resource ownership to the registry, guarantee allocation to every applicant, authorise routing control, import household vulnerability categories, create a rate base return, establish state ownership or enable general regulation of operator activities.

Because duties are contractual and technical as far as possible, providers can compete on performance while a uniqueness invariant remains common. Public law can add non-derogable protections within jurisdiction. The result is a public-service-level discipline without public-utility-state expansion.

A practical measurement schedule

A serious covenant needs a small set of indicators that operators can verify.

Targets should be based on observed operations and risk, not copied from electricity rules. Outcomes need distributions, not just averages. Severe cases, repeated failures and affected dependence should remain visible.

The schedule makes accountability concrete without giving the registry a wider mandate. It measures whether the bookkeeper performed the bookkeeper's consequential work.

Reform should start where the analogy is strongest

The first priority is a public adverse-action map for each RIR. List non-payment and other triggers, each notice, each service consequence, effect on certificates and directory, review, suspension, remedy, restoration and irreversible reissuance point. Existing documents provide much of the material but not always in a dependence-centred view.

The second is a function-specific service report. Build external measures for public access, authenticated updates, accuracy correction, transfers, RPKI publication and incident communication. Publish exceptions and denominator changes.

The third is cost separation. Reconfigure activity budgets around the narrow essential service, adjacent public interest work and contestable services. Publish allocation rules, reserve objectives and fee objectives without assuming that revenues equal costs.

The fourth is a claim suspension and independent remedy capable of stopping irreversible action. Start with factual, billing, identity and authority disputes where later correction would be difficult.

The fifth is provider succession. Define a portable record and conduct an independently observed exercise before institutional failure forces improvisation.

None of these steps require nationalisation or a global public utility commission. Each can be adopted by contracts, corporate rules, interoperable standards and applicable law. Their value can be tested before broader institutional claims are made.

Electricity regulation is useful here because it has learned to turn dependence into duties. The registry system can borrow the duties while refusing the state built for another machine.

Conclusion: copy the safeguards, not the sovereign form

Electricity regulators know that an indispensable service cannot be governed by good intentions alone. Performance needs units. Monopoly cost needs review. Interruption needs notice and restoration. A claim needs a decider who can halt irreversible action. Supplier failure needs a continuity arrangement. Conflicts around a bottleneck need separation and non-discrimination.

These insights apply to essential Internet number records. Registries should publish exact service commitments for access, accuracy, correction, authenticated modification, portability and identifiers. Fees should be linked to a narrow, verifiable service, with reserves and cross-subsidies visible. Termination should be decomposed into its real effects, preceded by proportionate procedure and followed by restoration when the ground fails. A successor provider should be able to preserve consistent state.

The analogy stops before ownership and command. IP addresses are not electricity. Registry databases do not carry traffic. RIRs do not operate territorially exclusive wires, balance a physical system or require a guaranteed return on a massive fixed plant. Universal electricity service does not create a universal IPv4 right. A national regulator's jurisdiction does not become a global digital mandate.

The most sophisticated electricity reforms since the 1990s have often separated common networks from competitive services rather than treating public ownership as the only answer. Number governance should take the same functional instinct further: keep the common layer thin, make its provider measurable and replaceable, and leave operator decisions outside.

The right comparison produces neither laissez-faire nor a public utility state. It produces a disciplined bookkeeper. Essential records receive public-service-level protections, while the institution that maintains them remains too narrow to become the government of the networks that depend on its work.

Sources

• RFC 7020, The Internet Numbers Registry System- registration accuracy, global uniqueness, registry hierarchy and separation of registration from routing operation.
• US Department of Energy, Electricity Distribution System Baseline Report- the regulatory compact, cost-of-service framework, obligation to serve, prudent cost recovery and ownership diversity.
• FERC Order No. 888- open, non-discriminatory transmission tariffs and separation of network control from competitive electricity sales in the 1990s.
• Directive 96/92/ECandDirective (EU) 2019/944- electricity market separation, unbundling, non-discrimination, network duties and consumer safeguards.
• Consolidated Directive (EU) 2019/944- current supplier of last resort, vulnerable customer, disconnection and dispute protections.
• Ofgem's Guaranteed Standards of Serviceand2025 payment update- defined service obligations and administrable payments for covered failures.
• Ofgem's Energy Network Price ControlsandRIIO-3 Final Determinations- the link between revenues, incentives, innovation, outcomes and sufficient network funding.
• Australian Energy Regulator's Distribution Service Target Performance Incentive Scheme- standardised interruption measurement and service performance-linked incentives.
• Australian Energy Regulator's Ring-fencing Guideline for Electricity Distribution- functional separation, compliance reporting and conflict controls around a regulated network.
• RIPE NCC Activity Plan and Budget 2026and2026 Charging Scheme- current activity, budget, account and fee evidence used to demonstrate the difference between total transparency and service-level cost allocation.
• ARIN Fee Schedule,billing process,revocation and restoration processandRegistration Services Agreement- a current example of staged non-payment, service suspension, revocation and restoration.
• RIPE NCC Closure of Members, Deregistration of Internet Resources and Legacy Resources- termination grounds, notice, service cessation, deregistration and RPKI certificate consequences.
• APNIC Fee ScheduleandMembership Agreement- current fees, termination for non-payment, reactivation and potential deregistration.
• NRS Charter- the premise of registry as bookkeeper and accurate registration used to limit the comparator.
• Lu Heng, The Bill of Rights of Uniqueness Coordination- the proposed operator rights to accurate records, notice, correction, continuity, portability, appeal and institutional replacement.
• Lu Heng, When the Water Company Says Your House Belongs to It- the adjacent stewardship versus ownership analogy, distinguished here from the article's specific electricity instruments.