[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
Tyler O'Meara
arin at tyleromeara.com
Fri May 30 17:16:06 EDT 2025
To clarify, I am not the author of this proposal.
This proposal should make no mention of "hobbyists" because it has no special
impact on "hobbyists".
"Hobbyists", as I would define them at least, are not prohibited from getting
resources from ARIN today. Nothing in the NRPM or ARIN business practice
precludes that. All that is required is that they set up some kind of legal
entity, commonly an LLC or Sole Proprietorship, which in many ARIN jurisdictions
is a trivial exercise.
I believe that this policy has the same impact on "hobbyists" that it has on
"non-hobbyists": removing the requirement to have some kind of organizational
structure that makes ARIN staff happy. Unless we view this requirement as some
kind of discriminatory hurdle meant to discourage "hobbyists" in particular (and
I don't), then I don't see any particular reason why a change to this
requirement should involve "hobbyists" at all.
As the authors mentioned in the comments, the only thing this changes is the
removal of the aforementioned restriction. All other requirements in the NRPM
remain the same.
I do not believe that the legal structure of the requestor of Internet Resources
has a material impact on the validity of that request from a policy or technical
point of view. Therefore, barring some legitimate legal issue not yet raised, I
support this policy.
Tyler
On Fri, 2025-05-30 at 15:46 -0500, David Farmer wrote:
> I would happily accept something like "legally recognized entity or business,"
> instead of just "legal business."
>
> Whether or not it is stated in the NRPM, it is the current operational
> practice. Further, the word organization would not usually be thought of as
> including individuals. I'm OK with including individuals operating a business
> in their own name. Still, this case is on the line for the definition of an
> organization, where individuals who are not operating a business and are
> strictly acting as hobbyists are on the other side of that line, in
> my opinion.
>
> If you intend this new definition to change the current operational practice,
> and include hobbyists, which you clearly do, you must make the case for
> changing the current operational practice. You don't get to define the current
> operational practice out of existence. Saying that RIPE allows it really isn't
> a reason for ARIN to allow it. One of the reasons the RIRs were created is to
> allow them to have different policies.
>
> Finally, while I'm willing to be convinced otherwise, I currently don't
> support including hobbyists. Still, the current text is far from explicit that
> hobbyists are to be included, and is even further from convincing me that such
> a change is a good idea.
>
> Thanks.
>
> On Fri, May 30, 2025 at 2:04 PM Tyler O'Meara <arin at tyleromeara.com> wrote:
> > Having some kind of legal structure which ARIN staff can verify is part of
> > ARIN's current business processes. It is not a requirement stated in the
> > NRPM.
> > In fact the term "organization", despite being used extensively in the NRPM,
> > is
> > not defined at all in the NRPM.
> >
> > ARIN staff has, in the absence of a proper definition, (likely correctly)
> > interpreted the term organization to exclude natural persons broadly, with
> > some
> > exceptions (such as sole proprietorships). However, they have not and do not
> > require that all organizations engage in business. In fact, many
> > organizations
> > like government agencies, NGOs and even international treaty organizations
> > are,
> > and should be, considered to be organizations.
> >
> > I will note that prior attempts to define organization in the NRPM have
> > failed,
> > usually because they have not been inclusive enough to capture what we
> > actually
> > mean. Personally, I think an "organization" for the purposes of the NRPM
> > should
> > be "an entity or subdivision thereof capable of entering into a legal
> > contract
> > with ARIN". Any restrictions on who or what can acquire resources, and for
> > what
> > purposes, belong in the sections defining justifications for those
> > resources.
> >
> > Tyler
> >
> > On Fri, 2025-05-30 at 13:38 -0500, David Farmer wrote:
> > > It is part of the current criteria. Further, calling a natural person, who
> > > is
> > > not acting as a business and is strictly a hobbyist, an organization seems
> > > a
> > > bit of a stretch to me.
> > >
> > > If you want to change things to include hobbiests, it should be a
> > > clear and
> > > explicit change, not something snuck in the back door of a fuzzy
> > > definition.
> > >
> > > Thanks.
> > >
> > >
> > > On Fri, May 30, 2025 at 1:21 PM Tyler O'Meara <arin at tyleromeara.com>
> > > wrote:
> > > > Why is "Operate as legal businesses within the ARIN service region" a
> > > > "fundamental criteria that must be included in the definition of an
> > > > organization"?
> > > >
> > > > That requirement does not seem self-evident to me.
> > > >
> > > > Tyler
> > > >
> > > > On Fri, 2025-05-30 at 12:59 -0500, David Farmer via ARIN-PPML 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
> > > > > > You are receiving this message because you are subscribed to
> > > > > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > > > > > Unsubscribe or manage your mailing list subscription at:
> > > > > > https://lists.arin.net/mailman/listinfo/arin-ppml
> > > > > > Please contact info at arin.net if you experience any issues.
> > > > >
> > > > >
> > > > > --
> > > > > ===============================================
> > > > > 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
> > > > > You are receiving this message because you are subscribed to
> > > > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > > > > Unsubscribe or manage your mailing list subscription at:
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> > > > > Please contact info at arin.net if you experience any issues.
> > >
> > >
> > > --
> > > ===============================================
> > > 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
> > > ===============================================
>
>
> --
> ===============================================
> 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
> ===============================================
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