Summary

  • The Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries is a proposed replacement for ICP-2; a recommended draft, a rationale report and next steps were published on 1 September 2026.
  • Whether such a text is a control surface or an intention turns on four questions: who decides, on what evidence, with what hearing, and what happens to number resources and member contracts.
  • The reviewed material establishes the process and answers none of the four; six specific questions about the draft's operative provisions were not obtained in this review, and that gap is itself the finding.

What the record establishes

On 10 November 2025 ARIN published an announcement stating that "the second consultation on the revised draft 'Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries' (RIR Governance Document) intended to replace Internet Coordination Policy 2 (ICP-2) has officially concluded" (ARIN, 10 November 2025). Read that sentence twice for what it does not do. It fixes a status (a revised draft), a lineage (a replacement for ICP-2) and a procedural milestone (a consultation closed). It describes no operative provision.

The Address Supporting Organization's own site carries the other half of the trail. It records that "in October 2023, the NRO Executive Council (EC) asked the ASO AC to establish and manage a process to update the ICP-2 document", adding that the update "will be conducted in consultation with each of the RIR and ICANN communities to enhance the RIR system's accountability to the broader Internet community" (ASO). The same page carries a dated entry: "1 September 2026 — Recommended Draft RIR Governance Document, Rationale Report, and Next Steps".

Together those records give a mandate, a drafting body, a consultation cycle and a published product. That is a genuine institutional sequence, and it is more than most governance exercises leave in public view. It is also entirely a record of process. Neither page states that a body has adopted the draft, that it has an effective date, or that it is in force.

The remaining chronology — a first consultation from 14 April to 27 May 2025, a second from 28 August to 7 November 2025, delivery of the recommended draft to the NRO Executive Council on 28 July 2026 — reached this review as a reported summary rather than as a dated publisher record, and is labelled accordingly. A trade report of 28 July 2026 calls the change the framework's first rewrite in 25 years and attributes to it a power to remove registries (Tech Times, 28 July 2026); that is the report's characterisation, and the provision behind it was not obtained.

The four questions

A derecognition instrument is not tested by whether it uses the word. It is tested by four questions, each with its own failure mode.

Who decides? The record establishes who ran the drafting and who received the result. Running a process is not holding a decision; a mandate to consult is not a mandate to determine. The distance between the two is exactly where a registry's exposure sits.

On what evidence? A criterion describes a condition. A standard of proof says how much must be shown, by whom, before the condition counts as met. Without the second, the first is a preference — and a preference cannot be audited.

With what hearing? An adverse finding with no stated right of reply, no reasons and no review path is an administrative act, not an adjudicated one. A member cannot price that risk; a registry cannot plan against it.

What happens to the addresses and the contracts? This is the question that reaches the operator. A registry's recognition functions as the practical title behind every allocation it has issued. A text that ends recognition without a rule for records, delegations and member contracts leaves the largest consequence unwritten.

Six gaps in the reviewed material

The operative provisions were the specific object of two of this review's five research requests. Both attempts failed — one on a routing and permission error, one on capacity — and the work stopped there rather than repeating the same class of request. Three requests succeeded, two failed. What the material obtained does not answer is concrete:

  1. The operative text of the Recommended Draft, in whole or in part.
  2. Any named body empowered to decide recognition or derecognition under it.
  3. Any evidentiary threshold, burden or standard of proof.
  4. Any right of response, hearing, statement of reasons, review, stay or cure.
  5. Any rule on disposition of number resources, delegations or member contracts.
  6. Any adopting-body resolution, effective date, or statement that the document is in force.

Those six are gaps in this review, not findings about the draft. A provision may exist. What is published here is that it was not obtained, and that the four questions therefore stay open on the record as reviewed.

What a member can rely on

Read the title and you learn the subject. Read the consultation record and you learn that a drafting process ran with unusual transparency. Read for the operative answers and the trail stops where the consequences begin.

The narrow, useful statement is this: a registry's standing still rests on arrangements the reviewed material does not describe. The instrument is a proposed replacement framework in recommended-draft form — the directory entry Only for Strategic Circle tracks it — and the next observable step is a decision by the body that received it. Until such a record appears, the silence belongs in the risk file, not the reassurance file.