ICANN Advisory Clarifies Registration Data Directory Services Email Requirements

The Internet Corporation for Assigned Names and Numbers (ICANN) today published an advisory to clarify the obligations of ICANN-accredited registrars related to the use of web forms in Registration Data Directory Services (RDDS).

The Registrar Accreditation Agreement and Registration Data Policy require registrars to publish a registrant's email address in their public RDDS in order to facilitate communication between third parties and domain name registrants. Registrars must also publish a registrant's technical contact email if the registrar collects that information. The Registration Data Policy that went into effect on 21 August 2025 gives registrars the option to publish a pseudonymized email address or a link to a web form instead of displaying the contact's email address. This option enables the registrar to align with global data protection practices.

ICANN is aware that at least one registrar has implemented a web form that only permits users to send a communication request to the registrant or technical contact. Submitting the form initiates a system-generated message stating that someone is trying to establish contact, but it does not allow users to send their own message or attachment.

This has raised questions among community members about whether that type of form complies with the requirement to facilitate communication. Some community members understand the phrase "facilitate email communication" to mean that the registrar must permit third parties to contact the registrant and communicate using their own words.

ICANN issued this advisory to inform the community about these web form implementation practices. The advisory clarifies how current obligations apply in such cases and explains the circumstances in which web forms will be deemed compliant as a way to facilitate communication.

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