Multiple LIR Accounts: Looking Back and Thinking Ahead

Since the early days of the RIPE NCC, members have been able to operate more than one Local Internet Registry (LIR) account under a single membership.

Originally, this addressed a small number of practical situations, such as organisations with multiple independent business units or companies that had merged while retaining separate operational structures.

Over time, however, the Internet registry landscape changed considerably. IPv4 exhaustion, the introduction of the last /8 policy and the emergence of an IPv4 transfer market created incentives that were never envisioned when multiple LIR accounts were first introduced.

Today, only a small percentage of members operate multiple LIR accounts, yet these accounts continue to create disproportionate operational complexity across many areas of the RIPE NCC.

This article looks back at how we arrived here, shares operational observations, what we have learned over the past decade, and explains why the current situation presents an opportunity for simplification.

A different model

In the early 1990s, the rapid growth of the Internet made the centralised management of IP addresses and AS Numbers unsustainable. This led to the creation of the hierarchical Internet Registry System that we still use today.

Within this model, the Regional Internet Registries (RIRs) receive large blocks of Internet number resources from IANA and manage their distribution within their respective service regions. Through a membership model, RIRs allocate these resources to Local Internet Registries (LIRs), typically Internet Service Providers, academic institutions, or enterprise networks. LIRs then assign address space to their customers or End Users and maintain the corresponding registration data.

This established a straightforward operational model: one organisation operates one LIR account. Consequently, RIPE policies, as well as the policies of the other RIRs, were written around the concept that an LIR represents a single member organisation.

Over time, however, the RIPE NCC took a slightly different approach.

A small number of members requested additional LIR accounts to simplify their internal administration. In some cases, one RIPE NCC member had acquired another and wanted to keep the existing registry accounts separate while integrating the businesses. In other cases, large service providers wanted separate LIR accounts for different business units or operational divisions.

These requests were understandable. At the time, the number of such cases was very small, the operational environment was considerably simpler than today, and accommodating them provided members with additional administrative flexibility. As a result, the RIPE NCC allowed multiple LIR accounts under a single membership, while the other RIRs continued to follow the one-organisation, one-registry-account model.

For many years, this approach worked well. The number of additional LIR accounts remained relatively stable at around 100 to 150, and the operational impact on both members and the RIPE NCC was limited.

IPv4 exhaustion changed everything

Everything changed in September 2012, when the RIPE NCC reached the last available /8 of IPv4 address space.

Under the RIPE policy at the time, IPv4 was no longer provided based on need and instead each LIR was entitled to receive one final /22 allocation from RIPE NCC’s remaining pool. This policy was written under the long-established assumption that an LIR represented a single member organisation.

As IPv4 became scarce and its market value increased, however, a somewhat predictable incentive emerged. Once the value of a /22 exceeded the cost of opening and maintaining an LIR account, creating additional accounts became economically attractive.

A small number of members quickly spotted this opportunity. Importantly, this was not an abuse of the policy. This was a consequence of the interaction between the RIPE policy and the RIPE NCC's operational model.

Initially, the number of additional LIR accounts remained fairly stable. At the time, members could open an additional account, receive their /22, transfer it almost immediately, and close the LIR account shortly afterwards. Many additional accounts therefore existed only briefly and never appeared as a significant increase in the overall statistics.

This changed in July 2015. After extensive community discussion, policy proposal 2015-01 introduced a 24-month holding period before IPv4 allocations received from the RIPE NCC could be transferred. The immediate effect was that members now had to keep these additional LIR accounts open for at least two years.

As shown in the graph below, the number of additional LIR accounts started to rise.

In November 2015, the RIPE NCC Executive Board temporarily suspended the creation of additional LIR accounts and asked the membership to decide whether this practice should continue. Although our analysis showed that most additional LIR accounts were being created to obtain extra /22 allocations for later transfer, which was clearly not the original intent of the last /8 policy, the Board concluded that prohibiting additional LIR accounts might simply encourage organisations to create multiple legal entities instead, each becoming a separate RIPE NCC member. That alternative would make resource holders less transparent and could also affect RIPE NCC governance, as each member carries its own vote. The Board therefore subsequently recommended allowing the creation of multiple LIR accounts again, and the membership voted in favour of this at the General Meeting in May 2016.

This decision effectively chose the more pragmatic of two imperfect options. While it helped organisational transparency, it also left the financial incentive untouched.

As the IPv4 prices continued to rise from 2016 onwards, the number of additional LIR accounts reached levels never seen before. By late 2019, more than 5,500 additional accounts existed, representing over 20% of all LIR accounts.

The graph below illustrates how this growth was distributed among members.

Some organisations held only one or two additional LIR accounts. However, a relatively small number of members opened dozens of additional accounts simultaneously. Many of these accounts were closed shortly after the 24-month holding period expired, with the associated /22 being transferred almost immediately. This strongly suggested that the accounts had primarily been created to obtain transferable IPv4 address space. We published a RIPE Labs article with more details on this topic in 2023.

The peak was reached in November 2019. This was also when the RIPE NCC exhausted its remaining IPv4 pool, and the policy changed again: from then on, only LIRs that had never received IPv4 from the RIPE NCC could receive a single recycled /24 allocation.

That changed economics. A /24 was worth considerably less than a /22, and demand for additional LIR accounts declined. The overall number of additional accounts began to fall, though with the expected delay caused by the 24-month holding period.

This trend reversed in 2021 when IPv4 market prices increased once more, making even recycled /24 allocations commercially attractive. This situation was mostly used by a few members who once again opened dozens of additional accounts simultaneously, as the economic benefit grew with the number of LIR accounts. Only from late 2023 onwards did the number of additional LIR accounts begin to decline significantly again, following a sustained decrease in IPv4 market prices.

The close correlation between IPv4 market prices and the number of additional LIR accounts suggests that, while some organisations might have administrative reasons for operating multiple accounts, the primary driver behind the rise of additional LIR accounts was economic rather than operational.

Before looking at the current situation, it is worth revisiting the assumptions that led the membership to continue allowing multiple LIR accounts in 2016.

Did the 2016 assumptions hold?

When the RIPE NCC membership voted in May 2016 to lift the temporary suspension on additional LIR accounts, the decision was based on three key assumptions:

• Maintaining additional LIR accounts attached to the same membership would provide greater transparency than encouraging organisations to create multiple legal entities.
• Allowing additional LIR accounts would reduce incentives to establish multiple memberships for governance purposes.
• Any remaining issues could be addressed through the RIPE Policy Development Process.

With almost ten years of operational experience, it is worth looking back at how these assumptions played out in practice.

Assumption: allowing additional LIR accounts would discourage organisations from creating multiple legal entities and memberships, which could reduce transparency and affect RIPE NCC governance.
The availability of additional LIR accounts may have reduced the incentive to create multiple memberships, but it never removed that possibility. Organisations willing to establish multiple legal entities could still do so. In practice, most organisations indeed chose the easier option of opening additional LIR accounts whenever this became economically attractive. Furthermore, creating and maintaining multiple legal entities has since become increasingly complex in many economies. Regulatory requirements, tax obligations, transparency rules and Know Your Customer (KYC) requirements have all become more stringent in most countries over the past decade, making this a considerably higher barrier than simply opening an additional LIR account.

We couldn't know how many organisations would have chosen this route had the option of additional LIR accounts not been available. What can be observed is that the straightforward option of opening another LIR account proved very attractive, as relatively few organisations appeared to pursue the more complex alternative.

Transparency has also evolved considerably since 2016. Over the past decade, the RIPE NCC has significantly strengthened its KYC processes, driven by both operational needs and regulatory requirements, including sanctions compliance. As a result, the RIPE NCC today has considerably better visibility into who controls member organisations than was the case when the 2016 decision was made.

Assumption: the remaining issues could be resolved through policy changes.
This proved difficult to realise. Discussions within the RIPE community concluded that the issue was not so much a policy loophole, but rather the RIPE NCC's operational decision to allow multiple LIR accounts under a single membership. Since RIPE policies are fundamentally written around the concept that an LIR represents a single member organisation, there was little appetite to redesign the broader policy framework to accommodate this operational exception.

The assumptions made in 2016 were reasonable given the information available at the time. However, nearly a decade of operational experience since then shows that the practical outcome differed in several important respects. Rather than reducing complexity, the operational exception for multiple LIR accounts continued to create strong economic incentives and increased the operational overhead for the RIPE NCC, while changes in regulation and the RIPE NCC's own processes reduced some of the concerns that originally supported maintaining this model.

With that hindsight, let's look at where we stand today.

The hidden cost of an exception

Looking back at the developments since 2016, one conclusion becomes clear: the number of additional LIR accounts tells only part of the story. Equally important is the operational complexity created by maintaining an exception to the original one-member–one-LIR model.

For many years, this complexity remained manageable. Individual process improvements and system enhancements addressed specific issues as they arose. However, as the RIPE NCC continued to modernise its services and automate more operational processes, supporting multiple LIR accounts under a single membership became an increasingly expensive exception.

Most RIPE NCC systems were originally designed around the assumption that a registry account represents one member organisation. Allowing several registry accounts for the same member introduces complexity at almost every layer of the organisation.

Some examples include:

• Fragmented member information. Contact details, billing entities, maintainers and communication preferences can differ between LIR accounts belonging to the same organisation, making it harder to maintain a consistent view of a member.
  
• Higher administrative workload. Activities such as audits, account closures, resource transfers and member updates often need to be handled separately for each LIR account, requiring additional coordination and manual effort. Additional checks are also needed before each General Meeting to ensure that the voting rights associated with a member are correctly assigned to the primary LIR account and denied to additional accounts, preserving the one-member-one-vote principle.
  
• More complex systems. Information such as resource holdings, sponsorship relationships and administrative records is managed at the LIR account level, while other processes operate at the member level. This makes even relatively small system changes significantly more complicated to design and implement.
  
• Additional billing and compliance effort. Different invoicing arrangements, contacts and payment responsibilities across multiple accounts increase the complexity of financial administration, compliance activities and fraud prevention.
  
• Resource management overhead. Multiple accounts encourage fragmentation of Internet number resources, often followed by later consolidation efforts that require additional work for both members and the RIPE NCC.
  
• Distorted perception of membership costs. A large number of multiple LIRs brings in additional fees, while any budget surplus is typically redistributed to the membership as a discount on the next year’s fees. Members who joined in the period between 2016-2022 therefore formed a distorted perception of what ‘normal’ fees looked like, which created friction in charging scheme discussions.

None of these challenges are overwhelming on their own. Together, however, they create a continuous operational cost that affects system development, process design and day-to-day registry operations. Especially in times of increased cost awareness and requests for more efficient use of the funding provided by members, this is too significant to ignore.

Could all of these issues be solved technically and operationally? Probably. But doing so would require significant investment into supporting an operational model that differs from the one on which the Internet Registry System and the RIPE policy framework is built.

A window of opportunity

Ironically, just as the operational costs have become increasingly apparent, the scale of the issue has become much smaller.

Following the peak in 2019, the number of additional LIR accounts has steadily declined, largely due to changing economic conditions: IPv4 prices fell, while the cost of maintaining LIR accounts increased. As a result, opening new additional accounts became less attractive, and many organisations closed accounts that had originally been created to obtain additional IPv4 allocations.

Today, the picture looks very different from just a few years ago. On 1 August 2026:

• 410 members (approximately 2.1% of the membership) operate multiple LIR accounts.
• Together they hold 708 additional LIR accounts, representing 3.4% of all LIR accounts.
• During the last 24 months, only 41 members opened additional accounts, creating 67 new LIR accounts in total.

From a membership perspective, this has become a relatively niche issue. Yet the operational complexity described above remains embedded in the RIPE NCC's systems and processes, affecting the organisation as a whole.

This creates an interesting situation. The impact on members has become smaller than ever, while the benefits of simplifying the operational model have increased.

At the same time, this opportunity may not remain open indefinitely. As long as additional LIR accounts remain possible, changing market conditions or future charging models could once again make opening additional accounts economically attractive. The experience of the past decade has shown just how quickly such incentives can influence behaviour.

In other words, while the operational burden is permanent, the current low number of additional LIR accounts presents a rare opportunity to address the issue with relatively limited impact on the membership. We therefore believe that now is the time to raise this topic with the RIPE community for further discussion and an opportunity to hear from members who still use multiple LIR accounts.

We plan to present on this at RIPE 93 later this year. In the meantime, please feel free to comment below this article or share your thoughts on the RIPE NCC Services Working Group mailing list.