[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
John Curran
jcurran at arin.net
Sun Jun 1 21:09:18 EDT 2025
David –
I’m not sure “hobbyist” is the clearest way to distinguish “natural persons not operating a business,” as it’s not uncommon for individuals who operate in a professional capacity to use a DBA or sole proprietorship to separate their public-facing activities from their private persona. This includes folks such as hobbyists, craftspeople, musicians, artists, and consultants who may not have paid engagements but still present themselves publicly and are reachable — sometimes for collaboration, sometimes simply for clarity regarding their non-personal activities.
Even without revenue, registering a DBA or sole proprietorship does establish a recognized business structure, and thus individuals doing so would be considered by many to be “operating a business,” regardless of any commercial intent.
ARIN’s use of the term Organization reflects our business practices of serving publicly identifiable, contactable entities capable of entering into contract — whether incorporated or not, for profit or not.
Thanks,
/John
John Curran
President and CEO
American Registry for Internet Numbers
p.s. Recent blog about Individuals obtaining number resources from ARIN - https://www.arin.net/blog/2025/05/28/individual-requests/
On Jun 1, 2025, at 7:36 PM, David Farmer via ARIN-PPML <arin-ppml at arin.net> wrote:
Actually I’m drawing a distinction between natural persons operating a business and natural persons not operating a business, I’m simply using hobbyists as clear example of that latter group. Hobbyist is about as far away from operating as a business I can think of.
To a certain extent, ARIN’s current practice already includes natural persons operating a business, but excludes natural persons not operating a business.
If we intend natural person in policy statement to include those not operating a business, like hobbyists, that is a change to current practices. Which is fine with me, but we should be explicit that this change is intentional. Maybe add “nature persons acting in any capacity” to the text or in the discussion make it clear natural person intentionally includes all natural persons, those operating a business or not, including hobbyists.
===============================================
David Farmer Email:farmer at umn.edu<mailto:Email%3Afarmer at umn.edu>
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE Phone: 612-626-0815
Minneapolis, MN 55414-3029 Cell: 612-812-9952
===============================================
On Sun, Jun 1, 2025 at 16:24 John Santos <john at egh.com<mailto:john at egh.com>> wrote:
You seem to be drawing a distinction between natural persons who are hobbyists and those who are not. Is that a distinction without a difference?
Should ALL hobbyists who otherwise meet the criteria be allowed to acquire Internet number resources, or should there be additional restrictions beyond those that apply to any business, sole proprietorship, partnership, government agency, NGO, educational institution, etc.?
Why should someone who meets all the requirements but is NOT a hobbyist be denied access to resources?
Could this all be resolved by adding additional requirements that automatically pertain to anything currently recognized as an "organization" by ARIN, but do not necessarily apply to all natural persons?
I think there is an unstated major premise in this argument, unstated by both sides.
I don't know what that premise is. I think I may be missing an important point.
The only way to determine, as far as I can tell, who is a hobbyist and who is not, is if that person self-identifies as a hobbyist. If so, anyone can do that. It is a meaningless legal distinction, and I support the proposal as written.
But maybe the unstated premise, if it were stated, might make clear why people are concerned about this. Maybe there should be some additional requirement beyond simply agreeing to the terms of the RSA? What are those requirements that would apply to a natural person, but either do not apply to an organization or are implicitly implied when an organization signs the RSA? Why isn't simply signing the RSA, abiding by its terms and paying any fees, sufficient?
-- John
On 6/1/2025 4:10 PM, David Farmer via ARIN-PPML wrote:
Thank you, Owen. My original point was that, as written, allowing natural persons without any language that restricts them to operating a business effectively allows hobbyists. As I said later in the thread, part of me is good with that; however, if we actaully intend hobbyists to be included, and at least some people supporting the policy, do intend hobbyists to be included, we need to be explicit about that being our intent, which the current text is not. So, with the current text, hobbyists are included as natural persons, but as written, that appears to be an unintended consequence. Therefore, we either need to be abundantly clear that we intend hobbyists to be included, or we need language restricting natural persons to operating a business if we don't intend hobbyists to be included.
In my original post, I focused on the latter part, providing language restricting natural persons to operating a business, and somehow, I lost the first part about being abundantly clear that we intend hobbyists to be included. Sorry about that.
Thanks.
On Sun, Jun 1, 2025 at 1:03 PM Owen DeLong via ARIN-PPML <arin-ppml at arin.net<mailto:arin-ppml at arin.net>> wrote:
+1
There are those that would consider my network in the “hobbyist” category. I’d argue that David’s use of the term here is the most vague part of the discussion in that there’s no clear line to differentiate hobbyist from business.
My network has ARIN resources and RIPE resources (the latter being the result of a convoluted need to resolve issues created by the ARIN board). Those resources are registered to “Owen DeLong and Family”. There are no corporations that I consider family members, so for better or worse, those resources were issued to natural persons.
While ARIN has consistently claimed that resources were always issued to organizations, not individuals, the meaning of that statement has morphed over the years without actual policy changes to support its evolution. Originally, it was intended to clarify that regardless of who the registered POCs on the resource were, the resource was registered to the ORG. For several years now, it’s been used as a cudgel to deny issuing resources to those who apply as individuals without first creating some form of organizational facade and more recently ARIN has started using it to require that facade be some form of legal business entity.
I support the policy as written and believe that rather than anything being snuck in through vague language, the policy clarifies prior policy intent which staff has drifted away from over many years of evolution.
Owen
On May 30, 2025, at 11:40, Matt Erculiani <merculiani at gmail.com<mailto:merculiani at gmail.com>> wrote:
I’ll double down.
What threat does a hobbyist pose to the global routing or Internet numbers systems?
Presumably someone going through this process isn’t your average home-labber; what’s the harm in them having a block of their own unique IPv6 if they pay the bill on-time? There are plenty of tunnel services that make this a viable option these days.
I’m prepared to be eaten alive for the suggestion.
Matt Erculiani
On Fri, May 30, 2025 at 12:30 Tyler O'Meara via ARIN-PPML <arin-ppml at arin.net<mailto:arin-ppml at arin.net>> wrote:
Hi Ben,
I don't think a categorical exclusion for "hobbyists" (whatever that actually
means in practice) is necessary or useful. The relevant sections for resource
justifications already require operating an actual network, so someone (or
organization) who wanted to come in and get IP addresses without running a
network would already be excluded. I suppose theoretically they could request a
single ASN, but if they're not planning on actually running a network that ASN
is worthless to them anyways.
I'll also note that not all valid use cases for acquiring resources necessitate
participating in global routing, although I doubt those use cases are
particularly relevant to natural persons. We should be careful not to
accidentally remove these use cases however.
Tyler
On Fri, 2025-05-30 at 11:12 -0700, Ben Shapiro wrote:
> Thank you David, for the thoughtful revisions and to ARIN staff for
> progressing this discussion.
>
> As someone involved in the operation of a small-to-medium Internet Exchange
> Point (IXP), I’d like to offer a complementary perspective from the
> interconnection and community network operator ecosystem.
>
> IXPs—particularly regional, volunteer-run, or lightly incorporated
> ones—frequently interface with a range of participants, including small ISPs,
> research networks, community fiber projects, and technically capable
> individuals who operate networks that meaningfully contribute to regional
> interconnection and resiliency. Some of these operators do not have formal
> corporate structures, yet they are deeply engaged in the technical and
> operational requirements of network management and peering. From our vantage
> point, the exclusion of natural persons from eligibility can pose an
> artificial barrier that does not align with real-world routing and
> interconnection practices.
>
> While I agree with David that natural persons operating legal businesses
> should unquestionably be considered valid organizations, I also see
> operational value in supporting natural persons who:
>
> * Operate autonomous systems used in peering environments;
> * Maintain IPv6 prefixes with global routing visibility;
> * Support last-mile, experimental, or community-focused efforts.
>
> Such actors are already required to justify their needs under existing ARIN
> policies. Adding verification of identity and residency, as the draft
> suggests, provides accountability without unduly excluding legitimate network
> operators who do not or cannot register as a business.
>
> From the IXP perspective, clarity is important. I support revising the policy
> language to explicitly differentiate:
>
> 1. Hobbyists with no operational network or intent to participate in global
> routing (not eligible),
> 2. Natural persons operating a routable, justified network (eligible), and
> 3. Natural persons operating a legal business (clearly eligible).
>
> A possible refinement might be:
>
> > An organization is a company, corporation, partnership, sole proprietorship,
> > government agency, non-profit entity, educational institution, or natural
> > person who operates a network consistent with ARIN’s resource justification
> > requirements and, where applicable, provides verification of identity and
> > residency. A natural person solely acting as a hobbyist is not considered an
> > organization.
>
> This language allows for policy consistency while acknowledging that technical
> legitimacy can come in many forms.
>
> Thank you for the opportunity to comment. I support further refinement of this
> proposal and appreciate ARIN’s responsiveness to community input.
>
> Best regards,
> Ben
>
>
> BEN SHAPIRO
> President | Willamette Internet Exchange
> president at thewix.net<mailto:president at thewix.net> | (541) 255-0280
>
>
> On May 30, 2025 at 10:59:00 AM, David Farmer via ARIN-PPML
> <arin-ppml at arin.net<mailto:arin-ppml at arin.net>> wrote:
>
> >
> > I do not support the policy as written. As written, it is unclear whether
> > natural persons not conducting business and acting solely as hobbyists are
> > excluded. However, natural persons operating businesses in their own name
> > should be considered valid organizations.
> >
> > Organizations must;
> > 1. Operate as legal businesses within the ARIN service region.
> > 2. Operate a network within the ARIN service region with Internet number
> > resources allocated by or registered with ARIN.
> > 3. Meet other policy or eligibility criteria.
> > From a policy perspective, the first two are fundamental criteria that must
> > be included in the definition of an organization.
> >
> > I suggest the following revision to the policy text;
> >
> > > 2.x Organization
> >
> > > An organization is a company, corporation, partnership, sole
> > > proprietorship, government agency, non-profit entity, educational
> > > institution, or natural person operating as a legal business within the
> > > ARIN service region. It must also operate a network within the ARIN
> > > service region with Internet number resources allocated by or registered
> > > with ARIN and meet other policy or eligibility criteria.
> >
> > I also want to point out the recent blog post by ARIN Staff about this
> > subject.
> > https://www.arin.net/blog/2025/05/28/individual-requests/
> >
> > Thanks.
> >
> > On Tue, May 20, 2025 at 12:33 PM ARIN <info at arin.net<mailto:info at arin.net>> wrote:
> > > On 15 May 2025, the ARIN Advisory Council (AC) accepted ARIN-prop-343:
> > > Resource Issuance to Natural Persons as Draft Policy.
> > >
> > > Draft Policy ARIN-2025-4 is below and can be found at:
> > >
> > > https://www.arin.net/participate/policy/drafts/2025_4
> > >
> > > You are encouraged to discuss all Draft Policies on PPML. The AC will
> > > evaluate the discussion to assess the conformance of this draft policy
> > > with ARIN's Principles of Internet number resource policy as stated in the
> > > Policy Development Process (PDP). Specifically, these principles are:
> > >
> > > * Enabling Fair and Impartial Number Resource Administration
> > > * Technically Sound
> > > * Supported by the Community
> > >
> > > The PDP can be found at:
> > >
> > > https://www.arin.net/participate/policy/pdp/
> > >
> > > Draft Policies and Proposals under discussion can be found at:
> > >
> > > https://www.arin.net/participate/policy/drafts/
> > >
> > > Regards,
> > >
> > > Eddie Diego
> > > Policy Analyst
> > > American Registry for Internet Numbers (ARIN)
> > >
> > >
> > >
> > > Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
> > >
> > > Problem Statement:
> > >
> > > ARIN policies currently restrict the issuance of number resources to
> > > organizations. This limits access for individuals who are running networks
> > > under their own legal name, especially in regions where forming or
> > > registering a business is not required or feasible. Other RIRs such as
> > > RIPE NCC allow individuals to receive resources directly. ARIN should
> > > consider similar flexibility to ensure equal and consistent access to
> > > Internet number resources for all operators, regardless of legal
> > > structure.
> > >
> > > Policy Statement:
> > >
> > > This proposal introduces explicit policy text into the NRPM to allow
> > > number resource issuance to natural persons (individuals) who provide
> > > valid justification and identity verification.
> > >
> > > Amend NRPM Section 2 to add the following definition:
> > >
> > > 2.18 Organization
> > >
> > > An organization is a company, corporation, partnership, sole
> > > proprietorship, government agency, non-profit entity, educational
> > > institution, or a natural person acting in a capacity consistent with
> > > operating a network and who meets ARIN’s resource eligibility criteria.
> > >
> > > Comments:
> > >
> > > Sections 4.2, 5.1, and 6.5 shall be interpreted to allow “organizations”
> > > as newly defined in Section 2.12, thereby including individuals where
> > > appropriate.
> > >
> > > Staff may develop identity verification and residency requirements
> > > appropriate to individuals (e.g., government-issued photo ID and proof of
> > > address).
> > >
> > > All resource justification, utilization, and RSA signing requirements
> > > remain unchanged.
> > >
> > > There has been extensive discussion of this topic on the ARIN Public
> > > Policy Mailing List (PPML) in April 2025. Participants have cited
> > > inconsistencies and barriers created by reliance on state-level business
> > > registries, and called for more inclusive eligibility mechanisms similar
> > > to other RIR regions. The proposal addresses these concerns while
> > > maintaining accountability and justification requirements.
> > >
> > > Timetable for implementation:
> > >
> > > Recommend implementation within 3–6 months of ratification to allow ARIN
> > > staff and legal counsel to develop supporting processes.
> > >
> > > Anything else:
> > >
> > > This proposal does not reduce the level of justification required to
> > > obtain resources, but merely expands eligibility to natural persons who
> > > operate networks and meet all existing technical and usage criteria.
> > >
> > >
> > >
> > >
> > >
> > > _______________________________________________
> > > ARIN-PPML
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> > > Unsubscribe or manage your mailing list subscription at:
> > > https://lists.arin.net/mailman/listinfo/arin-ppml
> > > Please contact info at arin.net<mailto:info at arin.net> if you experience any issues.
> >
> >
> > --
> > ===============================================
> > David Farmer Email:farmer at umn.edu<mailto:Email%3Afarmer at umn.edu>
> > Networking & Telecommunication Services
> > Office of Information Technology
> > University of Minnesota
> > 2218 University Ave SE<https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g> Phone: 612-626-0815
> > Minneapolis, MN 55414-3029 Cell: 612-812-9952
> > ===============================================
> >
> > _______________________________________________
> > ARIN-PPML
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> >
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===============================================
David Farmer Email:farmer at umn.edu<mailto:Email%3Afarmer at umn.edu>
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE<https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g> Phone: 612-626-0815
Minneapolis, MN 55414-3029 Cell: 612-812-9952
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