[council] Advisory: Registrar Implementation of the 2013 RAA's Whois Requirements

[Glen de Saint Géry <Glen@xxxxxxxxx>]

https://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
Advisory: Registrar Implementation of the 2013 RAA's Whois Requirements
31 July 2013
Purpose

This advisory is intended to help registrars understand which Whois fields must 
be populated pursuant to the 2013 Registrar Accreditation 
Agreement<https://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13-en.htm>
 immediately upon their signing of the agreement and which are not required 
until 1 January 2014.

Background

The 2013 Registrar Accreditation Agreement ("RAA"), like earlier forms of the 
registrar accreditation agreement, requires registrars to operate web-based and 
port 43 Whois services that provide public access to certain enumerated 
registration data fields. Section 
3.3.1<https://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13-en.htm#3.3.1>
 of the RAA specifies required data fields, such as the name and address of the 
registered name holder, and name, address, email address, and phone number of 
the administration and technical contacts for each domain name (among other 
required data elements).

The 2013 RAA, unlike previous versions of the registrar accreditation 
agreement, also includes a Registration Data Directory Service (Whois) 
Specification<https://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13-en.htm#bookmark2>
 which, among other things, describes a mandatory format registrars must use 
when publishing Whois data. This format includes a number of fields that were 
not required by earlier versions of the RAA. As examples, the Registration Data 
Directory Service (Whois) Specification requires registrars to include in their 
Whois output the email address and telephone number of the registrar's abuse 
point of contact as well as the IDs or handles used by the registry to identify 
the domain name and its contacts.

Because the 2013 RAA includes a number of new operational responsibilities for 
registrars that could reasonably take weeks or months to implement, the 
agreement also incorporates a Transition 
Addendum<https://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13-en.htm#bookmark21>.
 The Transition Addendum describes a number of obligations for which ICANN will 
not require registrar compliance until 1 January 2014. By way of example, 
registrars are not required to fully implement an abuse point-of-contact (see 
section 
3.18<https://www.icann.org/en/resources/registrars/raa/approved-with-specs-27jun13-en.htm#3>
 of the RAA) until 1 January 2014.

Some registrars have asked ICANN to clarify whether they must immediately begin 
populating Whois data with fields, such as the abuse point-of-contact email 
address and telephone number, even though they are not yet required to comply 
with the underlying obligation.

Required Whois Fields

The Transition Addendum to the RAA explicitly references a list of RAA 
provisions for which registrar compliance is not required until 1 January 2014. 
The Registration Data Directory Service (Whois) Specification is not included 
within that list of provisions. Accordingly, registrars are immediately 
required to comply with obligations described in that specification, including 
the obligation to format Whois data as defined in the specification. Registrars 
are not, however, required to include in their Whois output, data elements that 
don't yet exist or are not already in the registrar's possession. This includes 
reference to the items for which compliance is not yet required.

To be clear, registrars who are subject to the 2013 RAA must continue to 
include all of the fields described in section 3.3.1 of the RAA in their Whois 
output and the data elements they have within their possession. Registrars are 
not, however, required to include the following fields in their Whois output 
until 1 January 2014 (although registrars may, and are encouraged to, comply 
earlier):

Registry Domain ID
Registrar Abuse Contact Email
Registrar Abuse Contact Phone
Domain Status
Registry Registrant ID
Registrant Phone
Registrant Phone Ext
Registrant Fax
Registrant Fax Ext
Registrant Email:
Registry Admin ID
Registry Tech ID
DNSSEC
Last update of WHOIS database

Glen de Saint Géry
GNSO Secretariat
gnso.secretariat@xxxxxxxxxxxxxx
http://gnso.icann.org