ICANN's associated-domain checks, and the commenters drawing the evidentiary line

The GNSO’s DNS Abuse Mitigation PDP 1 initial report proposes Associated Domain Checks: a registrar shown actionable evidence that one domain is engaged in DNS abuse would be required to investigate other domains tied to that customer account or registrant. Eight preliminary recommendations, five implementation-guidance items, and comments open through 28 September at 23:59 UTC. Via CircleID.

The filings support the mechanism and argue about its evidentiary limits. Fatima Cambronero’s 21 September submission splits the evidence into three tiers — what triggers a check, what connects further domains to the check, and what supports acting against a particular associated domain — and argues that association should trigger investigation rather than establish that the second domain is abusive. She backs excluding compromised domains from triggering a check at all: a hacked domain should not bring scrutiny onto its registrant’s other names. The ISPCP constituency, filing 22 September, supports the recommendations as a package, prefers flexible criteria over rigid ones, says weaker or circumstantial indicators should not be determinative on their own, and asks ICANN to measure false positives, appeals and reinstatements when it evaluates whether the policy is operating proportionately. Karen Yousefi and Laura Ndubi press the registrant side: incorrect associations disrupt legitimate domains, so objective criteria, proportionality, and a route to challenge an adverse action.

Domains share registration data, hosting infrastructure and naming patterns without sharing malicious control, which is the whole difficulty. The proposal moves registrar obligation past the domain named in the abuse report, toward the bulk-registration behaviour Interisle put at a 10 percent floor and a likely 20 percent of 2025 gTLD registrations. The working group begins reviewing submissions at ICANN87 in Bali.

An obligation to investigate association, with the criteria for association left flexible, puts the cost of a wrong call on the registrar and the consequence on the registrant.