Summary

  • The draft's Article 6 defines derecognition as a multi-stage procedure: written proposal, publication and written response, independent RIR assessments with conflict-of-interest disclosure, ICANN review, and an ICANN decision that can approve derecognition only if supported by two-thirds of the RIRs excluding the subject RIR.
  • Three parties can start the process — any RIR, a member group of at least 25% of the subject RIR's members or 2,000 members (whichever is lesser), or ICANN — but ICANN cannot decide alone.
  • The quiet change of the word "Maintenance" to "Operation" in the instrument's title is the clearest editorial signal of what version 3 is for: describing ongoing operational compliance, not registry ownership.

A procedure, not a threat

Version 3 of the Governance Document for the Recognition, Operation, and Derecognition of Regional Internet Registries, dated 1 September 2026 and marked FINAL DRAFT on the NRO's consultation page, is the instrument that would replace the Internet Coordination Policy-2 adopted on 4 June 2001 https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/. The NRO notes that its HTML version is provided for community consultation and that the PDF is the authoritative text — a caveat that matters when reading provisions at this level of detail https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/.

Article 6.1 sets the substantive trigger: an RIR may be derecognized only if it does not continue to materially meet all the requirements of Section 4.1 and, despite a reasonable opportunity to remedy the failure through compliance and rehabilitation processes, remains materially non-compliant https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/. Two conditions are cumulative: material non-compliance with the recognition requirements, and the exhaustion of a reasonable opportunity to cure.

Who can start, and what they must say

Article 6.3 enumerates the initiators. A Proposal for Derecognition may be submitted in writing by any RIR; by a group of Members of the subject RIR consisting of at least 25% of its total Members or 2,000 Members, whichever is lesser, with each legal entity counted once; or by ICANN https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/. A valid proposal must state reasons and identify the specific Section 4.1 provisions allegedly breached — the draft, in other words, requires the accusation to be legible as a compliance question rather than a political one.

Article 6.4 then obliges the other RIRs and ICANN to publish notice that a proposal was received, and gives the subject RIR a reasonable time to provide a written response before consideration proceeds https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/. The ARIN 56 presentation by the ASO Address Council describes these as deliberate protections: minimum requirements for a derecognition proposal, a written-response opportunity for the affected RIR, and a requirement that ICANN publish the reasons for its decision https://www.arin.net/participate/meetings/ARIN56/materials/arin56_asoacupdate.pdf.

Evidence with declared interests

Article 6.5 requires each RIR other than the subject RIR to independently assess the proposal and provide ICANN a Derecognition Assessment with reasons, plus disclosure of actual, potential or perceived interests — expressly including familial or financial relationships https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/. In an industry where the five RIRs are simultaneously peers, competitors for members and counterparties in transfers and inter-RIR services, forcing assessors to disclose interests is the provision that makes the two-thirds vote meaningful.

ICANN's role is review, then ratification

Article 6.6, which the NRO's summary of differences identifies as new in version 3, has ICANN publish the proposal, the response and the assessments (with confidential material redacted after consulting the RIRs), make inquiries, request an RIR reconsider its assessment, and apply a Rehabilitation Requirement that restarts review https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/ https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3-summary-of-differences-and-rationale-for-changes/. The NRO frames 6.6 and 6.7 as aligning the derecognition process with recognition and emphasizing rehabilitation over proceeding to removal https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3-summary-of-differences-and-rationale-for-changes/.

Article 6.7 makes ICANN the final decision-maker, but not an independent one: approval of a derecognition proposal is possible only if it is supported by two-thirds of the RIRs, excluding the subject RIR https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/ https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3-summary-of-differences-and-rationale-for-changes/. On approval ICANN issues a Notice of Decision with reasons and coordinates a Notice of Pending Derecognition including a Transition Plan; on rejection it publishes its reasons https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/.

Article 6.8 describes the effects: RIR Services hand off to a successor or interim entity such as a Temporary Emergency Operator, and the derecognized RIR ceases providing RIR Services and loses NRO membership and decision-making authority https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/.

What the title change means

The first-round draft produced in the first half of 2025 was titled "Governance Document for the Recognition, Maintenance, and Derecognition of Regional Internet Registries"; the second-round revised draft switched to "Operation" https://www.nro.net/policy/internet-coordination-policy-2/process-for-the-review-of-icp-2-and-timeline/. The ASO AC's ARIN 56 deck gives the stated rationale: "Operation" better describes the nature of the operational requirements in the document https://www.arin.net/participate/meetings/ARIN56/materials/arin56_asoacupdate.pdf. Read against Article 6, the shift matters: legitimacy is framed as continuous operational compliance with Section 4.1 requirements, verifiable and curable, rather than as a status to be maintained at ICANN's discretion.

Where the draft stands

The ASO AC delivered the recommended draft to the NRO EC on 28 July 2026, transferring responsibility; approval and adoption are slated for Q4 2026 https://www.nro.net/policy/internet-coordination-policy-2/process-for-the-review-of-icp-2-and-timeline/ https://www.nro.net/aso-ac-delivers-recommended-draft-rir-governance-document-to-nro-ec/. Version 3 reflects the RIR consultation and ICANN Public Comment held from 28 August to 7 November 2025 and subsequent workshops, including ICANN 85 in Mumbai in March 2026 and ICANN 86 in Seville in June 2026 https://www.nro.net/aso-ac-delivers-recommended-draft-rir-governance-document-to-nro-ec/ https://aso.icann.org/recommended-draft-rir-governance-document-rationale-report-and-next-steps/. Until adopted by the RIRs and ICANN, it binds no one.

BTW's prior reporting noted that the public change summary omitted how the assessment denominator is calculated; the instrument text answers it — the two-thirds threshold counts only the RIRs excluding the subject RIR https://btw.media/en/new-rir-draft-excluded-assessment-denominator-public https://www.nro.net/policy/internet-coordination-policy-2/rir-governance-document-version-3/.

The caveats are real: the HTML text is non-authoritative relative to the PDF, several NRO and ASO pages carry no visible publication dates, and this reading rests on the consultation text rather than an independent inspection of the authoritative PDF. But on the text as published, the draft's derecognition machinery is designed to make unilateral removal impossible: no proposal without a compliance hook, no decision without disclosed-interest assessments, and no ICANN action without two-thirds of the subject's peers.