[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
David Farmer
farmer at umn.edu
Fri May 30 20:49:40 EDT 2025
Let's be intellectually honest, if you want to eliminate the requirement
for an organizational structure altogether, remove the word "organization."
The word "organization" strongly implies an organizational structure, and
beyond that, probably a legally recognized organizational structure; even
something as simple as operating a business in your own name is a legally
recognized organizational structure. Removing the requirement for that
legally recognized organizational structure is not the simple policy change
you think it would be. Such a change will likely have legal and operational
considerations that go well beyond just policy and impact the fiduciary
responsibilities of the board of trustees. This is why the board of
trustees has the final approval of policy.
Take it from someone with several decades of industry experience and more
than a decade on the ARIN AC; If we want individual hobbyists included in
the scope of this change, and part of the inner geek in me would love that,
we need to be very explicit about that kind of change. The fact that
individual hobbyists are within the intended scope of the change needs to
be much more clearly identified than it is currently. Simply tweaking the
definition of the word "organization" isn't explicit enough, in my opinion.
Furthermore, if, as I speculate above, this change impacts the fiduciary
responsibilities of the board of trustees, we will also need much more
justification for a change of that nature. The current justification, that
RIPE allows natural persons, isn't going to be enough to justify such a
change.
Thanks.
On Fri, May 30, 2025 at 4:16 PM Tyler O'Meara <arin at tyleromeara.com> wrote:
> 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:
> > > > > > 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
> > > > ===============================================
> >
> >
> > --
> > ===============================================
> > 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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