Updated: How ICANN Implemented the Registration Data Policy Into Operational PracticeIsabelle Colas-Adeshina

Implementing a new ICANN consensus policy, particularly one as comprehensive as the Registration Data Policy that went into effect on 21 August 2025, is no small feat. It requires careful planning, coordination across the organization, and significant updates to internal systems, processes, and procedures. At ICANN, our teams closely tracked the policy's development to understand how it would affect our operations. In the years leading up to the policy effective date, we outlined the framework and identified where adjustments to procedures and systems development would be needed to effectively implement the Registration Data Policy. This blog highlights key operational improvements that were made to implement the Registration Data Policy:

• Generic Top-Level Domain (gTLD) RDAP Profile: The profile provides technical and operational requirements to domain name registries and registrars on how to implement the Registration Data Access Protocol (RDAP). Like WHOIS, RDAP enables users to access current registration data but with standardized data access and query response formats. The ICANN organization (org) worked with a group of gTLD registries and registrars to update the gTLD RDAP Profile to follow the requirements of the Registration Data Policy.
• Emergency Back-End Registry Operators (EBERO) Program: The EBERO Program acts as a safeguard in the event a gTLD registry operator cannot maintain the five critical registry functions. Ensuring the availability of these functions protects registrants and provides an additional layer of protection for the Domain Name System. Under the Registration Data Policy, processing requirements imposed on the registry operator such as data collection and data escrow of nonpublic data and disclosure of such data to third-party requestors were updated.
• Extensible Provisioning Protocol (EPP): This underlying technology enables communication of registration data between registrars and registries. Updates included removing data fields that are no longer required, which necessitated changes to the EPP base protocol. In addition, EPP extensions were introduced to handle optional technical contact data where needed.
• ICANN-approved Data Escrow Agent: The existing provider practices were updated to align with policy requirements. For example, contact details for the administrative and billing contact are no longer required to be included in escrow deposits.

Additional Background

The Registration Data Policy is an ICANN consensus policy that outlines the requirements for gTLD registry operators and registrars regarding the collection, transfer, publication, and retention of domain name registration data. It stems from the recommendations of the Expedited Policy Development Process on the Temporary Specification for gTLD Registration Data, including Recommendation 27, which called for a review of existing policies and procedures to determine needed changes. The ICANN Board directed the ICANN org to collaborate with the Implementation Review Team to assess the impacts of these changes.

Following this review, several existing ICANN consensus policies and procedures were updated to reflect current operational and technical requirements called for in the Registration Data Policy. This assessment was carried out in phases: Wave 1 (active consensus policies, reported in February 2020), Wave 1.5 (policy recommendations in implementation, reported in February 2021), and Wave 2 (procedures such as EBERO and data escrow). These updates ensure the policy is consistent, relevant, and aligned with today's data protection and operational needs.

For more information about the policy and the organizational updates, please refer to the Registration Data Policy Implementation Resources webpage.