Summary

  • LACNIC’s Board decided on 24 May 2026 to activate charges for IPv4 transfers arising from mergers, acquisitions and name changes under policy 2.3.2.17 at the same amounts used for transfers between unconnected organisations under 2.3.2.18. It also approved annual inflation adjustment, with 2027 values to be adjusted.
  • The current corporate-transfer page publishes the two fee bands and the inflation method, but it does not say who is liable, whether an advance applies, when a payment becomes final, how rejection affects it or what counts as a separate charge. LACNIC’s intra- and inter-regional transfer pages do state those mechanics.
  • Different transaction types need not share an identical workflow. They do need a public rule that lets an applicant identify the applicable schedule, payer, billable unit and settlement state. A thin charge-incidence receipt would supply that rule without exposing confidential deal documents.

The invoice has more than one number

On 24 May 2026, LACNIC’s Board considered a staff recommendation about transfer fees. The recommendation was carefully bounded. Charges for transfers resulting from mergers and acquisitions under section 2.3.2.17 would be activated at the same amounts already applied to transfers between organisations without a relationship under section 2.3.2.18. The fees would then be adjusted annually for inflation, starting with the values for 2027. Coordination with the national internet registries would continue. The Board approved the proposal unanimously.

The visible result is now easy to quote. LACNIC’s page for a transfer caused by a merger, acquisition or change of name lists US$1,000 for a block from /24 up to, but not including, /19, and US$1,500 for a /19 or larger. It says the values are adjusted each year using accumulated inflation over the twelve months ending on 30 September, announced in October and effective on 1 January. The reference is the US consumer price index published by the Bureau of Labor Statistics.

That is a meaningful improvement. A company preparing a reorganisation can see a current amount and an update rule instead of treating the fee as an unpublished administrative variable. The Board minutes provide the decision trail. The page links back to the resolution. None of this should be discounted merely because the amounts are small beside the value of a corporate transaction or the scarcity premium of IPv4 addresses.

But a fee is not fully described by its amount. It also has an incidence: the person or organisation on which the obligation falls. It has a trigger: the point in the procedure at which a provisional estimate becomes an amount due. It has a unit: one request, one counterparty, one block, one corporate act or some other object. It has a state after approval, denial, withdrawal or correction. And, when the schedule is indexed, it has a version date.

The public corporate-transfer page does not answer those questions. It does not identify the party that pays. It does not say whether the US$200 advance described on other transfer pages applies. It does not state whether any payment is refundable if the legal documentation is rejected or the transfer does not proceed. It does not explain how several blocks, subsidiaries, predecessors or counterparties are counted. It does not mark the procedural event that fixes the applicable fee.

This is not evidence that LACNIC lacks answers. It is evidence that the answers cannot be reconstructed from the public page checked for this article.

The neighbouring pages expose the difference

The comparison is unusually clean because LACNIC publishes more of the settlement logic for intra-regional and inter-regional transfers. Those pages use the same US$1,000 and US$1,500 bands. They also say that the requesting organisation in the LACNIC region—whether offering or receiving the addresses—pays US$200 before the justification is analysed. If the request cannot be justified and is not approved, that advance is not refunded. After approval, the receiving organisation pays the balance. Transfers involving different offering organisations are treated independently and attract individual fees.

Those sentences allocate risk. Before the registry has approved a transfer, someone must finance a non-refundable diligence step. After approval, another obligation falls on a named side. When more than one offering organisation is involved, the unit of charging is not left to intuition. The rule lets a buyer, seller, broker, counsel or finance team turn a web page into a closing checklist.

The merger path publishes the same endpoints but not the connecting sequence. Equality of amount therefore creates a misleading visual symmetry. A reader can see two identical price bands and reasonably assume that the associated mechanics travel with them. The Board resolution does not establish that. It approves the same amounts, not a wholesale incorporation of every procedural sentence used for section 2.3.2.18.

The distinction matters most at the edges. A name change may involve no economic sale and no obvious “receiving” party. A statutory merger may extinguish one legal person and continue another. An asset acquisition may transfer only part of a network. A group reorganisation may move several address blocks among related entities. Those facts can justify a different charging rule. They also make it unsafe to borrow the ordinary-transfer rule without an explicit cross-reference.

A corporate transfer is not simply a sale

LACNIC has a strong defence. Transfers between unconnected organisations are recognisable market transactions. The registry can identify an offering organisation, a receiving organisation and a justification review. A merger or name change is often a continuity problem instead: the legal wrapper changes while the network, customers and operational control may continue. Forcing both paths into an identical deposit and payer sequence could be artificial or wrong.

The registry may also disclose the missing information inside the case. An applicant could receive an invoice, payment instructions and a calculation once staff understand the corporate structure. Some configurations may be too varied for a short public page. A page that already gives the fee bands, indexation method, governing policy and Board minutes is not an exercise in concealment.

That defence should set the limits of the criticism. There is no basis here for saying that LACNIC overcharges, collects a secret fee, sends inconsistent invoices or misapplies its policy. There is no observed dispute, failed closing or operator outage. The absence of a public sentence is not proof of an absent internal rule.

Yet case-specific administration and public predictability are not substitutes. An applicant often needs to allocate responsibility before opening a case: the purchase agreement may assign registry costs; a board approval may require a transaction budget; a lender may need conditions precedent; a public-sector successor may require procurement authority. “Staff will tell you later” can be operationally sufficient and contractually late.

Nor does the proposed transparency require every corporate permutation to be reduced to one formula. The public rule can state that the liable party or charging unit is determined after classification, then name the classification states and the record that makes the determination final. What matters is that the discretion has an observable surface.

Inflation turns timing into substance

Annual indexation makes the missing trigger more important. LACNIC’s published method uses inflation accumulated through 30 September, announces the revised values in October and applies them from 1 January. A case opened in December and completed in January may therefore touch two schedules. Which one controls: submission, documentary completeness, approval, invoice or registry update?

The public sources examined do not answer that question for corporate transfers. The answer may already be settled in billing systems or individual notices. But without a published rule, two parties drafting a cost clause cannot know which date to anchor. The problem is not forecasting US inflation. It is identifying the event to which the forecast applies.

The same point applies to the billable unit. A single merger can carry several IPv4 blocks. A reorganisation can involve more than one predecessor or successor. If a fee attaches per case, the corporate act may define the unit. If it attaches per independent transfer, counterparties or resource bundles may divide it. The ordinary-transfer pages resolve one version of that problem by saying that different offering organisations are treated independently. The merger page supplies no equivalent statement.

These are modest sums in many deals. Modest sums can still reveal institutional quality. Large commercial parties can absorb an unexpected additional fee; small networks, non-profits, public bodies and distressed successors may have rigid approval paths. More importantly, a predictable registry is one in which a rule can be cited by both sides before either side has to rely on a discretionary email.

The smallest useful record

LACNIC does not need a new policy cycle to close the public gap. It needs a charge-incidence receipt attached to each transfer path. The receipt could be a short table or a versioned machine-readable object. It should identify the policy clause and case type; the fee schedule, version and effective date; the block, bundle, counterparty or corporate-act unit; the party liable for any initial and final amount; the advance, if one exists; the effect of approval, denial, withdrawal and correction; the inflation observation period; the invoice trigger; and the route for contesting a classification or calculation.

For a complicated case, the public receipt could say that staff will determine a field after reviewing specified evidence. The applicant-visible record would then carry the actual determination without publishing confidential merger agreements, ownership charts or legal opinions. Rules become inspectable; documents remain protected.

Such a receipt would also preserve history. If a case crosses the annual adjustment date, the record could show which schedule was bound and why. If an invoice is corrected, the superseded version would remain intelligible. If a successor later audits its address holdings, it could distinguish the registry fee from the legal event that moved control.

The larger institutional lesson is narrow. Price transparency is not complete when the numbers are visible but the obligation is not. LACNIC’s Board has made the important decision to bring corporate transfers into a published fee architecture and to prevent that architecture from decaying in real terms. The next step is not more publicity. It is to make the charge travel with a small, durable account of who owes what, under which version, at which stage and for which unit.

Sources