We have implemented a temporary feature for any members and other resource holders concerned that they might be forced to transfer their IP addresses to another party due to threats or coercion. This article explains how this feature works, what it does and does not prevent, and who can activate it.
We recently announced that we would implement a voluntary registry lock that is available to all resource holders who want it. This feature has been introduced in response to concerns raised by Ukrainian community members at RIPE 85 – that people in Russian occupied territories might be intimidated or threatened into transferring their Internet number resources to another entity.
As we explained at that meeting, finding a workable solution to address these concerns was not a simple matter, because: 1) as a neutral membership organisation we treat all members consistently; 2) the Standard Service Agreement we sign with members requires us to provide them with services; 3) we must comply with RIPE policies.
These requirements mean that many of the seemingly obvious solutions are either unworkable or risk exposing the RIPE NCC to various legal risks. At the 163rd meeting of the RIPE NCC Executive Board on 14-15 December, it was decided that we should offer a registry lock functionality to all resource holders on an opt-in basis.
How the lock works
The lock is available to all RIPE NCC members and holders of Provider Independent (PI) resources in our service region. Once activated, it applies to all of their resources and prevents them from being transferred to another entity via what we sometimes call a ‘policy transfer’. It remains in place for a six-month period and cannot be removed before this time has elapsed.
The lock does not prevent resources from being transferred in cases of merger or acquisition, or in bankruptcy cases where a liquidator has been appointed. This is because the change has already occurred – i.e. the company that holds the resources no longer exists, and so the registry needs to be updated to reflect reality.
Once the lock is in place, we expect that Ukrainian resource holders will continue to transfer resources of their own initiative – including to Russia – and it is important to be clear on this point upfront.
How to activate the lock
Members can apply the registry lock through the following steps:
1. Log in to the LIR Portal and press the ‘Request an update’ button.
- Select ‘My LIR details and resources’ if you are requesting the lock for your own resources
- Select ‘My customer's name and resources’ if you are sponsoring LIR for an End User with Provider Independent (PI) resources)
2. A menu with four options will appear – select the fourth option ‘None of these options are relevant to me, please open a ticket'. Include some details to explain your situation and upload the signed Registry Lock Request Form
- The form must be signed by someone authorised to represent the company, such as the company owner or Managing Director. We will require additional documentation proving the status of the company or that the person signing on behalf of the company is authorised to do so
3. Members who cannot submit their request via the LIR Portal can send us an email instead (firstname.lastname@example.org). In this case, we will need to perform additional due diligence checks to establish the identity of the requesting party.
4. The lock will be activated from the moment we receive a request. We will then determine whether the request is properly authorised. If so, all resources will remain locked and prevented from policy transfers for a period of six months. The ability to set additional locking periods will depend on the outcome of RIPE policy discussions (see below).
Note: to avoid abuse, in cases where we cannot verify whether the person submitting a request is authorised to do so via an online registry, we will require notarisation of the signature and the official registration document confirming this. We are also applying the highest levels of due diligence to all requests from resource holders in Ukraine. As part of this, we are requiring that supporting documents be notarised for requests to lock resources from resource holders in this country.
Action from the RIPE community is needed
Everything that we do regarding the registration of IP addresses and AS Numbers is firmly based in the policies set by the RIPE community. We cannot limit the rights of paying members without either a solid legal basis or a clear mandate from the RIPE community.
The resolution from our board allows us to offer this lock as an option until 1 July 2023. If the RIPE community wants this to be available on a more permanent basis, we will need a mandate in the form of a policy. This period is therefore intended to give the community time to propose and discuss a change to its policies.
Our Policy Officer is available to offer guidance and administrative support to get the proposal through the RIPE Policy Development Process (PDP). If the community has not reached consensus by this July deadline, we will not be able to apply any new lock requests that we receive and any existing locks will not be able to be renewed once they have expired.