[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons

Fri May 30 14:12:22 EDT 2025

 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 | (541) 255-0280

On May 30, 2025 at 10:59:00 AM, David Farmer via ARIN-PPML <
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> 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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>>
>
>
> --
> ===============================================
> David Farmer               Email:farmer 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
> ===============================================
> _______________________________________________
> ARIN-PPML
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