Summary

  • The NRO’s recommended RIR Governance Document would give an incumbent registry three years after the document takes effect to meet obligations genuinely absent from ICP-2, including its implicit duties.
  • Section 7.3 creates a classification question with money and authority behind it: each duty must be identified as old or new before a compliance clock can be explained.

Three years sounds generous until someone has to decide what the clock covers. At the end of the NRO’s recommended governance document, Section 7.3 gives an affected regional internet registry a “reasonable but specific” period to fix practices that conflict with the document. For obligations genuinely new to RIRs, it specifies three years after the document comes into force. Its crucial qualifier is that those duties must not already have been contained or implicit in ICP-2.

That word gives the reform its hardest argument. The 2001 ICP-2 criteria already set tests for a new regional registry: community support, impartiality, financial and operational sustainability, and other foundations of recognition. The proposed replacement is far more explicit. Article 4 turns continuing financial independence, governance, transparent records, service stability and cooperation with audits into auditable commitments. A registry could call a newly written procedure a new duty. A reviewer could answer that the procedure merely makes an old standard measurable. The difference is up to three years of compliance time.

The document has another sharp edge. Section 1.3 allows ICANN and the RIRs to develop joint implementation procedures, but says an absent procedure does not prevent a provision from being enforceable. Waiting for an implementation manual would therefore be a poor substitute for deciding which obligations are already live when the document itself takes effect. Amendment grace periods, meanwhile, must be specified in the amendment; they do not inherit a universal three-year holiday.

The NRO’s current FAQ says the ASO Address Council delivered the recommended draft to the NRO Executive Council on 28 July 2026. The Council has the next steps, including coordination with ICANN and the RIRs. The review timeline records the consultation and recommendation process. Neither record supplies an adoption date. The proposed three-year clock has not started, and there is no honest calendar deadline to print.

Before a final text takes effect, the useful public document is a line-by-line transition table: the old ICP-2 basis, the new clause, whether it is genuinely new, the affected RIR, and the applicable start and end dates once known. Without that table, a promise of staged compliance can become a private argument about when oversight is allowed to begin.