Summary

  • ARIN-2025-1 entered Last Call on 28 October 2026, with comments due by 11 November. The proposal would define ISP explicitly as a type of Local Internet Registry and replace many ISP references in the policy manual.
  • Its current section 4.2.3.1 says LIRs “should” keep documented justification for each reassignment and reallocation. ARIN staff recommended “must” in June; the August text still says “should.”
  • The draft’s implementation timetable says “Immediate.” Staff estimates six months for training and changes to public material, procedures and applications.

A policy document can change an institution’s vocabulary without settling every verb behind it. ARIN’s proposal gives Local Internet Registry, or LIR, the broad job title. It explicitly describes an Internet Service Provider as one type of LIR; universities and large enterprises can also fall under the LIR definition. The Advisory Council sent that text to Last Call on 28 October. The community has until 11 November to challenge its final wording before the Council weighs the comments and a possible Board decision.

The most revealing line sits in section 4.2.3.1. An LIR is required to apply a utilization efficiency criterion when giving addresses to customers. For each reassignment and reallocation, it should have documented justification available. ARIN may ask for that material at any time; failing to provide it may affect future allocations. The current NRPM uses the same “should” for ISPs, so the draft preserves the existing modal verb while changing the institution’s name.

ARIN staff called out the verb in its 15 June review. Staff recommended must, saying the stronger word would align the documentation sentence with ARIN’s ability to request the evidence and with the stated consequence if it is absent. The review assessed a May version. The proposal dated 13 August still contains should. The published record shows the difference; it gives no reason for retaining that wording. A commenter can now ask whether the final policy intends to preserve the old evidentiary expectation or state a mandatory file-keeping duty.

There is a second clock on the same page. Under “Timetable for Implementation,” the proposal says one word: “Immediate.” Staff calls the text implementable and says it would not materially change how ARIN evaluates requests, yet estimates six months to train employees and revise public documentation, internal guidance and applications. Immediate legal effect and six months of operational work can coexist, but the proposed text provides no phase schedule tying one to the other. If the Board adopts it, the date when applicants see consistent labels and guidance will matter more than the one-word timetable.

The November 11 comment deadline is the live decision point. A revised final text or a published implementation schedule could answer both questions. Until then, the proposed vocabulary is clear; the evidence verb and the clock deserve the same care.

Sources