Hi all,

I send this already to gtld-tech group and was then pointed to this group.


I wanted to ask if anyone has thought about the impact of NIS2 on EPP, 
especially the validation of domain holder?

There are many issues here regarding protocol and processes. It would be good 
to work together here and create some guidelines.

Some Registries have plans to implement some registrar verification process or 
already have done it.
Other registries may say it should be done on Registrar side.

From my point of view, we will probably have to deal with several models.

There will probably be registry validated or registrar validated models, with 
all their different forms.

Of course the legislation will not be the same everywhere and there will be 
different requirements per registry.

But it would be useful if registries and registrars agree on a set of rules.

Some that come to my mind ad hoc
- Visibility in public services (WHOIS/RDAP)
- Billing process:
  - Directly billed and then on HOLD until verification.
  - Billing only after successful verification
- Handling of documents, if any are needed only the validator should request 
them.
- Handling of registrant changes and transfers.


Regards
Marco


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