Summary

  • The ASO Address Council’s recommended third draft has moved to the NRO Executive Council for finalization; it is not yet adopted or in force.
  • ICANN has started costing implementation and possible ongoing operations, but its Finance Committee minutes describe no funding approval request at the August meeting and only anticipate a future Project Fund request.

When a new governance document arrives, attention naturally goes to what the text permits. The recommended Version 3 of the Regional Internet Registry Governance Document has plenty to examine: recognition, audits, compliance reviews, rehabilitation plans, emergency continuity and derecognition. But another question now sits beside the legal text: what would it take to operate those provisions, and who will pay for the work?

That question has become concrete. ICANN’s Board Finance Committee minutes for 25 August, published on 5 October, say staff are evaluating the feasibility of the proposed framework, identifying capabilities ICANN may be asked to develop, and estimating costs. The minutes say no funding approval was being requested at that meeting. They anticipate a future Project Fund request that could support a three-year implementation period and recoup ICANN operating costs incurred during earlier implementation phases. The same discussion flags potential ongoing operating costs after implementation.

Those sentences are not an approved budget, a price tag, or evidence that a later funding request has or has not been made. They are a useful early record of the transition from drafting rules to planning an institution that may have to administer them. The central issue is whether the final adoption path will be matched by a clear, fundable implementation path.

A draft has changed hands, not become law

The Address Supporting Organization Address Council (ASO AC), acting as the NRO Number Council, completed its drafting work and delivered a recommended Version 3 document to the Number Resource Organization Executive Council (NRO EC) on 28 July. On 1 September, the ASO AC published the draft, its redline against Version 2 and a rationale report. The NRO process page says responsibility for finalization has now moved to the NRO EC, which will coordinate further updates and determine next steps with ICANN.

That sequence matters. “Recommended draft” is not the same status as “approved framework.” The NRO lists community presentations at LACNIC 46, ICANN 87, ARIN 58 and RIPE 93 later in October, with the approval and adoption stage still upcoming in Q4 2026. As of 8 October, the procedures for approval and adoption remained to be determined by the NRO EC and ICANN. The three-year compliance period in Version 3 therefore has not begun.

The recommended document would make the framework more operational than ICP-2’s original entry criteria. It describes regular audits and targeted compliance reviews, identifies who may request some reviews, provides for a rehabilitation plan in some cases, and sets out temporary emergency continuity arrangements. It also gives ICANN and peer registries roles in evaluating recognition and derecognition proposals. These are proposed duties and procedures, not demonstrated activities under an adopted regime.

A grace period answers only one question

The draft gives each RIR three years after the document comes into force to comply with new obligations that were not already contained or implicit in ICP-2. That provision offers a transition window. It does not itself say how much the work costs, which capabilities must exist at each point, how those costs are shared, or what long-term operating model should follow.

The Finance Committee record begins to describe that missing operational layer. ICANN staff said the work-plan development phase was expected during FY27 and could involve internal labour, professional services, contractor support and outside counsel. The committee discussed both total implementation cost and the possibility of ongoing ICANN operating costs once the transition is complete. The minutes also describe a possible funding route: a future Project Fund request could pay for the three-year implementation period and recoup operating costs incurred earlier.

The distinction between setup and operation is not bookkeeping trivia. A time-bounded project may pay to build procedures, tools, templates or review capacity. A continuing compliance function may need staff, recurring audits, secure record handling, legal support and the ability to respond when a review is triggered. A funding decision that covers one without identifying the other could leave the institution with an adopted responsibility but no durable operating basis. That is a risk to test, not a failure the minutes establish.

The draft’s provisions indicate why the cost exercise could be more than a one-time document update. Recognition and derecognition assessments may have to be prepared, reviewed, disclosed and reasoned. Audits are to occur no less frequently than once every five years; targeted compliance reviews can be requested or, in some cases, initiated by ICANN. A rehabilitation plan may require follow-up verification. Emergency continuity can demand rapid coordination when an RIR cannot provide all or part of its services. Each mechanism implies work, but the reviewed records do not publish a cost estimate, staffing table or final work plan.

Funding is part of the governance design

If the framework is adopted, ICANN may become responsible for activities that require new capabilities, while the RIRs take on new obligations of their own. The allocation of work and the allocation of money will therefore shape how the framework functions. The question is not simply whether the document includes a transition clause. It is whether the institutions expected to carry out each step have a defined owner, a viable resource path and a way to account for ongoing costs.

This is particularly important where the same institution would assess compliance and support remediation. A capability built only for launch can be inadequate if reviews recur. Conversely, treating every new function as a permanent program before its scope and trigger are clear could overstate costs. A credible plan should make these distinctions visible rather than place them in one aggregate number.

The public record supports a narrow conclusion: ICANN has started feasibility and cost planning; its Finance Committee did not approve funding at the 25 August meeting; and staff anticipated a later Project Fund request while also flagging ongoing costs. It does not support a claim that funding is unavailable, that ICANN has failed to plan, or that the proposed document is unworkable. It also does not show a final request, Board decision or funded implementation schedule.

The next test is whether those states become connected. Community sessions can clarify the document’s final scope. The NRO EC and ICANN can explain how approval and adoption will work. ICANN’s FY27 work planning can turn the broad capability list into a staged, costed plan. A later funding request can specify what is one-time implementation, what is recurring operation, which prior costs it would recoup and what happens after the three-year transition.

The distinction between authority and capacity is the practical lesson. A rule can authorize a review, but someone must be prepared to conduct it. A transition period can defer compliance, but it cannot tell institutions how to build the required capability. And an anticipated fund request is not an allocation. Version 3 remains a recommendation. The governance question now is whether its eventual approval will be accompanied by a transparent account of the people, systems and recurring resources needed to make the framework work.

Sources

  1. ICANN Finance Committee minutes, 25 August 2026
  2. ASO AC Recommended Draft RIR Governance Document, rationale and next steps
  3. NRO RIR Governance Document Version 3
  4. NRO process for reviewing ICP-2 and timeline
  5. Heng Lu, Note 62: “Mandate Laundering: From RIR Fantasy to Transition Architecture” (editorial lens only)