Summary

  • A policy can say “immediate” while its supporting systems take longer to align.
  • ARIN-2025-1 remains in Last Call through 11 November; no allocation decision has changed.

A number-resource applicant can ask a deceptively simple question: does ARIN mean an ISP, an LIR, or both? The answer matters most when the label reaches a form, an internal procedure or a staff instruction. ARIN’s current draft says “Immediate” for implementation. Its staff review budgets six months for the paperwork and software that make the terms consistent.

That is not one clock running late. It is two clocks measuring different work. The policy text would take effect immediately if adopted; ARIN’s supporting material would take longer to catch up. The draft remains in Last Call through 11 November 2026, so neither clock has started as a final policy decision.

The proposed distinction is concrete. An LIR would be an Internet Registry that belongs to an RIR, receives number allocations from it, and allocates them to customers, end users and its own infrastructure. The examples include large enterprises and universities as well as internet service providers. The proposed ISP definition is broader in another direction: it lists connectivity, web services, colocation, dedicated servers, virtual private servers and VPNs.

The draft says all ISPs are LIRs, but not all LIRs are ISPs. ARIN staff describes the intent the same way: ISP is a type of LIR, not a synonym. Yet the proposal’s ISP definition describes services; the LIR definition describes an organization’s place in the registry chain. Those are different tests. The text has to explain how they meet before a form can reliably apply them.

That distinction reaches beyond a glossary. The draft replaces ISP with LIR in several NRPM sections on allocations, additional requests and reassignments. Staff says the changes would not materially alter registry operations or how requests are evaluated. At the same time, “ISP” appears across ARIN’s web content, documentation, internal procedures and applications. Staff lists training, public documentation, internal procedures and applications as implementation requirements, and estimates six months.

The policy’s own timetable says “Immediate.” Staff’s implementation estimate says six months. Read together, they describe an immediate policy date and a longer period for aligning the tools and explanations around it. The record does not provide a deployment sequence or identify which applications change first. It also contains no evidence of requests misclassified under the current wording. Those are the missing facts that would change the operational risk assessment.

The practical test is consistency at the point of use. If a request form says ISP while the NRPM section says LIR, staff guidance must tell applicants how the terms relate. If an application uses the label as a branching rule, that rule must match the approved policy text. An updated manual alone cannot do either job.

ARIN’s Advisory Council moved the draft to Recommended Draft Policy status in August. It appeared on the ARIN 58 policy docket in October. The current policy page gives the Last Call deadline as 11 November. The membership and public-policy process still has to decide whether this wording advances.

Sources