Internet Number Resources Review by AFRINIC (Arnaud Amelina, Jean-Baptiste Millogo, Marcus Adomey)

Archived draft page metadata · The captured DRAFT01 page uses 'Review' in place of 'Audit' in its title, labels the draft Archived rather than Under Discussion, and shows Date Submitted 2018-04-09 instead of Date 18 May 2016. It also replaces the named-author list with a reference to the proposal tab. The audit, recovery, appeal and reporting clauses remain substantively unchanged, and the revision history still records the first draft on 18 May 2016; the metadata differences do not establish a new policy amendment.

Audit and review terminology · Draft 2 consistently describes regular reviews where Draft 1 calls them audits. The stated basis remains the RSA and allocation/assignment policies, so this terminology change alone does not establish a new recovery power.

Complaint wording and staff interpretation · The complaint clause changes from requiring investigation to warranting investigation. The added staff assessment interprets that wording as allowing staff to decide which complaints merit review and notes workload and unjustified-complaint concerns. That interpretation is identified as staff commentary, rather than an additional adopted criterion.

Express finality of arbitration · Draft 2 removes the words 'and without appeal' from the description of arbitration outcomes while retaining 'unequivocal'. The text does not define a further appeal route, so the deletion is not treated as creating one.

Staff objection to a routing-visibility ground · The added assessment says AFRINIC has no policy or contractual basis to treat lack of global routing visibility as a violation and recommends addressing that issue separately. Draft 2 still lists lack of visibility among its proposed recovery grounds; staff criticism does not itself remove the clause.

Staff objection to deleting holder history · Draft 2 adds staff concerns that removing previous-holder records conflicts with existing practice of retaining traceable history after returns or transfers. The proposed recovery clause still says records will be removed; the assessment is an objection, not a completed amendment.

Staff privacy concerns about reporting · New staff comments identify potential conflicts between full transparency or compliance reporting and NDAs, the RSA or law. The annual member-level compliance-report requirement remains in Draft 2; the assessment does not by itself replace that requirement with a privacy-qualified report.

Staff estimate for an appeal process · The added assessment estimates three to six months to create and consult on an appeal process, followed by about two months to appoint volunteer arbitrators. This is a historical implementation estimate; it is not a policy deadline or evidence that the process was established.

Staff and legal view of existing authority · The draft-2 page adds a staff/legal assessment arguing that existing RSA obligations already support review and recovery and that the proposal mainly makes the process clearer. This is the assessment's stated position, not a new legal conclusion or an expansion of authority inferred from the draft.

Evidence and evaluation of complaints · Draft 3 requires complaints to be backed by evidence and explicitly assigns AFRINIC staff the evaluation of the facts when deciding whether to conduct a review. Draft 2 has the complaint trigger but does not include those requirements in the operative clause.

Protection against a repeat reported review · Draft 3 excludes a member with the same resource portfolio from this reported-review provision when a full review was completed in the preceding 24 months. The qualification is attached to the Reported class; it is not described as a universal prohibition on every kind of review.

Policy references in the rationale · Draft 3 cites the Consolidated Policy Manual sections 5.5, 6.5 and 7.0 instead of the earlier standalone IPv4, IPv6 and ASN policy identifiers. This updates the rationale's references and does not itself change the resource-review criteria.

Integration into the Consolidated Policy Manual · Draft 4 explicitly proposes inserting CPM section 13, including a general review-and-recovery statement and renumbered operative clauses. Draft 3 presents the rules as proposal section 3. The principal RSA/policy-compliance basis is retained.

Grounds listed for recovery · Draft 4 narrows the listed grounds to breaches of AFRINIC policies or the RSA and other legal agreements. It removes the explicit non-exhaustive framing and separate examples concerning routing visibility, a non-operating organisation and unauthorised transfers. Those deletions do not imply that conduct breaching the retained policy or agreement criteria is permitted.

Retention of previous-holder records · Draft 4 changes the post-recovery instruction from removing the previous holder's records to updating them in AFRINIC's databases. The preceding contact, rectification and three-month publication period remain.

Who may appeal a review result · Draft 4 permits reviewed members who are not satisfied to appeal, replacing Draft 3's wording about a result that does not appear fair. Both preserve the published arbitration process and describe its outcome as unequivocal.

Privacy-qualified annual reporting · Draft 4 changes the annual report from identifying reviewed members and their compliance levels to describing review activities, expressly in accordance with the Mauritius Data Protection Act and member NDAs. This is the wording of the historical proposal, not a present-day assessment of legal compliance.

Duplicate draft with conflicting page metadata · Both pages identify Draft 4 and contain identical problem statement and operative review, recovery, appeal and reporting clauses. Their captured submission dates and status labels differ: 11 April 2017 / Under Discussion versus 5 April 2018 / Archived. This is a metadata discrepancy between copies, not a substantive policy amendment or an inferred chronology.

Population for random reviews · Compared with the retained Draft 4, Draft 6 selects random reviews from the membership generally, removing the listed membership-category restriction. This is a comparison of the two retained texts; it does not establish which intervening draft first introduced the change.

Form of complaint evidence · By Draft 6, staff may, after assessing the evidence in a community complaint, require a sworn affidavit or a declaration before a Commissioner of Oath. Draft 4 requires evidence and staff evaluation but lacks this express option. Draft 6 does not require an affidavit for every complaint.

Transfers as an alternative during recovery · Draft 6 expressly takes account of a transfer meeting other AFRINIC-approved needs before publication for recovery and permits transfer to other members during the three-month publication period. Draft 4 mentions seeking compliance during that period without this express transfer wording.

Time window to appeal · Draft 6 adds a four-week appeal window to the dissatisfied member's right to appeal. The quoted clause does not yet specify what starts that period; the comparison does not invent a starting event.

Arbitration framework · Draft 6 refers to arbitration under Mauritius's Code of Civil Procedure and makes AFRINIC's suggestion of volunteer arbitrators conditional on a request from an aggrieved party. Draft 4 instead calls for AFRINIC to define and publish the process and pool, and describes the outcome as unequivocal. The comparison reports the proposed wording without determining present legal rights.

Reporting standard and applicable rules · Draft 6 calls the annual review-activities report meaningful and refers broadly to all applicable laws and regulations, replacing Draft 4's express references to the Mauritius Data Protection Act and member NDAs. Removing those named references does not establish an exemption from any otherwise applicable obligation.

Evidence coverage of the same Draft 6 · Both retained pages identify AFPUB-2016-GEN-001 Draft 6. The full page contains proposed review, recovery, appeal and reporting clauses, while the following capture contains a problem summary and revision-history notes without those operative clauses. This is a reduction in captured evidence, not evidence that the review powers or safeguards were repealed. The full Draft 6 remains the source for those provisions.

Inconsistent submission and status metadata · The full-page capture labels Draft 6 archived and gives a submission date of 5 April 2018; the summary labels the same draft under discussion and gives 10 April 2018. These conflicting page-level metadata do not establish that the proposal was reopened, nor do they date an archival or policy-status transition. Keep the discrepancy visible without treating capture order as legislative chronology.

A summary-only baseline limits comparison with the complete Draft 7 · The older capture contains a Draft 6 problem summary and revision history, but no operative sections. The Draft 7 capture adds the complete proposed review, recovery, appeal and reporting framework. This expands the available evidence; it does not establish that every newly visible clause was introduced in Draft 7 or that the proposal became adopted policy.

Draft 7 documents a minimum recovery period and discretionary extensions · Draft 7 specifies at least six months to return resources, except for fraudulent acquisition or unlawful usage and abuse, and requires negotiation of a longer term for cooperative members restoring compliance or needing time to renumber. Staff retain discretion over acceptable compliance and the extension length. Its revision history identifies section 13.4(A) as the Draft 7 change; the summary-only older capture cannot establish the complete prior clause.

Added staff assessment records unresolved recovery and confidentiality questions · The Draft 7 capture includes a May 2019 staff and legal assessment absent from the older summary capture. Staff seek clarity on the period allowed in fraud or abuse cases, which resources must be reclaimed, and members' ability to correct a breach or notify changes in usage; legal counsel raises confidentiality concerns about publishing recoverable resources. These are recorded assessment concerns, not evidence of adoption, rejection or an adjudicated legal outcome.

Eligibility for a random review · Draft 8 limits random selection to members not reviewed for other reasons in the preceding 24 months. Draft 7 selects from the membership without that qualification in the random-review clause. The separate same-portfolio restriction under reported reviews remains.

Scope of resource recovery · Draft 8 expressly confines the recovery process to the portion of addresses found noncompliant. Draft 7 directs AFRINIC to initiate recovery without that express limitation in the corresponding sentence. The six-month provision, its fraud/unlawful-use exception and the possibility of a longer negotiated term remain.

Start of the appeal period · Draft 8 clarifies that the four-week appeal period starts when AFRINIC communicates the review results. Draft 7 provides four weeks without specifying the starting event in that clause.

Captured proposal status · The Draft 7 page is labelled Archived and the Draft 8 page Expired. These are retained page labels, not evidence of the date of expiry or adoption. The comparison preserves that distinction from the operative draft changes.