At the RIPE NCC we’re busy working out the implementation of Numbered Working Item (NWI) 10, which deals with clarifying the meaning of the country code attribute in the RIPE Database and the Extended Delegated Statistics.
Back in 2018 and 2019, during RIPE 77 and RIPE 78, we presented about the lack of a clear definition for the Country Code attribute. This attribute is present in both the RIPE Database and the Extended Delegated Statistics for the Internet number resources that the RIPE NCC allocates and assigns to LIRs and their End Users.
In general, the Country Code refers to the country where the network is located. But, what does that actually mean? Well, it's complicated.
There are different interpretations as a network can be spread over multiple countries and this can also change over time. Also, there is no proper way to verify if the Country Codes entered are correct, so we have to believe what the user tells us. In addition to the above, we have been receiving an increasing number of requests to update the country code in the Extended Delegated Statistics. This is why we have decided to look into this problem and propose a solution to the community.
Here’s what we proposed:
- The Country Code for resource objects in the RIPE Database will remain as is, maintained by the resource holder who decides the criteria.
- A new attribute will be added to the ORGANISATION object, with the Country Code for the country in which the resource holder is legally based. This attribute will be maintained by the RIPE NCC.
- This new Country Code attribute will also be reflected in the Extended Delegated Statistics. Hence, this file will show in which country the resource holder is legally based.
This will make our data more consistent with that of other Regional Internet Registries (RIRs), as most of them use the legal country where the holder is registered.
The community takes over
We understood that country codes are used by community members for different purposes (e.g. commercial) and therefore we needed to have the community’s support before taking action and changing things.
The RIPE Database Working Group (DB-WG) took over the issue and started a discussion on how the Country Code attribute should be defined. After some months of discussion in the mailing list, the DB-WG Chairs announced that consensus was reached on our proposal and that we could start the implementation.
Getting our tools ready
Before going forward with the implementation, we had to make sure we had the following information ready in our systems:
1. The RIPE Database needs to have the "country:" attribute available for ORGANISATION objects.
The RIPE Database part is ready! The "country:" attribute is now available and can be added in the ORGANISATION objects for entities that hold both Provider Aggregatable (PA) space and Provider Independent (PI) resources.
2. The legal address for our members
We have the legal address of each of our members (LIR) already in place, digitalised in our internal records.
3. The legal address for our members’ End Users (holders of PI resources)
While working on the bits and bobs of the implementation plan, we realised we first had an obstacle to bypass. We have the legal address of End Users who hold Provider Independent resources, but they are only available in the registration papers we have approved upon requesting the resources via their Sponsoring LIR. The problem is that this information is not yet in the right format in our system (see Phase 2 below for more details).
We will first update the ORGANISATION objects with "org-type:" 'LIR' and include the "country:" attribute. The value of this attribute will be taken from our internal records.
At the same time, we will also update the Country Code in the Extended Delegated Statistics file for all the resources an LIR holds. These resources will have as Country Code the Country Code that will be visible in the respective ORGANISATION object.
This is expected to be done by the end of 2020. An announcement will be sent once this is completed.
We will need to update the functionality of our tools so as to be able to digitally edit the legal addresses for End Users that hold Provider Independent resources. This is already in progress. However, we estimate that it will take some time. If everything goes according to plan, our tools will be ready within next year.
Once our tools are ready, we will need to manually add the legal address for all End Users. At the time of writing, the total number of End Users that hold Provider Independent resources is 19,383.
At that moment, further adjustments will need to take place in our existing requests forms (e.g. resource requests, update requests), where Sponsoring LIRs will be required to add the legal address of their End User upon submitting a new request to the RIPE NCC on their behalf.
Once we have the legal address recorded for all End Users, we will be able to repeat Phase 1. This means updating the ORGANISATION objects with "org-type:" 'OTHER' and include the "country:" attribute, if that org-id is referenced to a Provider Independent resource. The value of this attribute will be taken from our internal records.
At the same time, we will also update the Country Code in the Extended Delegated Statistics file for all the Provider Independent resources an End User holds. These resources will have as Country Code the Country Code that will be visible in the respective ORGANISATION object.
Important to note:
Once Phase 1 is completed, the change of the Country Code in the Extended Delegated Statistics file will only be possible if there is proof from the National Authorities that the legal entity has been moved to another country. LIRs will need to contact the RIPE NCC and submit documentation proving the need to update, for example due to a business restructure (merger/acquisition). Nothing new here - This is the current standard process for updates on the legal information of any LIR/End User. Sponsoring LIRs can contact us directly at any moment to fix incorrect country codes for their End Users.
Please note that the maintainer of the INET(6)NUM objects in the RIPE Database will still be able to update the Country Code. However, any changes on the "country:" attribute in the resource objects will not impact the Extended Delegated Statistics.