<div dir="ltr"><div id="gmail-:2j9" class="gmail-Am gmail-aiL gmail-Al editable gmail-LW-avf gmail-tS-tW gmail-tS-tY" aria-label="Message Body" role="textbox" aria-multiline="true" tabindex="1" style="direction:ltr;min-height:376px" aria-controls=":4e0" aria-expanded="false">Hello PPML,<div><br></div><div>Doug Camin and I are shepherding ARIN-2025-4. We received the completed ARIN Staff and Legal review this afternoon. Staff has provided a long and detailed analysis of the impact of this policy which is available on the ARIN website. <a href="https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025">https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025</a></div><div><br></div><div>In summary, ARIN staff believes that this policy cannot be implemented as written as it would significantly change ARIN's business practices, which is outside the scope of the Policy Development Process (PDP). They suggest that this change is better suited for the ARIN Consultation and Suggestion Process (ACSP).</div><div><br></div><div>As shepherds, we feel that it is important to collect as much feedback as possible from the community on this proposal which has generated significant interest here on PPML. We welcome your further input on the staff and legal analysis to help us shape the next steps.</div><div><br></div><div>I won't fill all of your inboxes with the full text but have provided a few snippets below that describe ARIN staff's understanding of the business impacts at a high level.</div><div><br></div><div>"The reformulation of Organization to include the addition of “natural persons” represents a substantive change to ARIN’s current service model, as it would redefine that scope of ARIN’s customer base. ARIN’s General Counsel noted to the ARIN AC that such a change was likely outside of the scope of the ARIN PDP and that expanding ARIN’s customer community to directly include natural persons could have potential implications for how ARIN is treated under law and regulation."</div><div><br>"Legal Review: Draft Policy 2025-4 proposes that ARIN issue Internet number resources directly to natural persons/individual customers. Historically, ARIN has issued such resources only to legal, business entities with an established operation and appropriate justification, including sole proprietorships. The proposed change would shift ARIN’s operational model from business-to-business (B2B) to one that would include business-to-consumer (B2C) relationships.</div><div><br></div><div>This type of change to ARIN’s operations would necessarily involve a substantial number of legal and operational issues as well as a long implementation timeline given the number of issues that would need to be resolved. There would also need to be a review and likely updates to most, if not all, of ARIN’s service terms, agreements, and applicable operational policies and communication materials."</div><div><br></div><div>"If adopted, ARIN 2025-4 would materially alter ARIN’s risk profile by introducing consumer-facing obligations and exposures. While the policy’s intent looks to simply enhance inclusivity, it is a very complex proposal that proposes changing the nature of services that ARIN offers, with corresponding changes to how ARIN is treated in multiple legal, tax, regulatory regimes. Proper implementation will require significant investment to determine the full extent of the legal, operational, and compliance adaptations necessary, as well as determining resulting implementation cost. A further, in-depth review of the final policy text would be necessary prior to implementation, including analysis of contract, insurance, tax, data privacy, compliance, and any other applicable impacts."</div></div></div><br><div class="gmail_quote gmail_quote_container"><div dir="ltr" class="gmail_attr">On Tue, May 20, 2025 at 1:33 PM ARIN <<a href="mailto:info@arin.net">info@arin.net</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">On 15 May 2025, the ARIN Advisory Council (AC) accepted ARIN-prop-343: Resource Issuance to Natural Persons as Draft Policy. <br>
<br>
Draft Policy ARIN-2025-4 is below and can be found at:<br>
<br>
<a href="https://www.arin.net/participate/policy/drafts/2025_4" rel="noreferrer" target="_blank">https://www.arin.net/participate/policy/drafts/2025_4</a><br>
<br>
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:<br>
<br>
* Enabling Fair and Impartial Number Resource Administration<br>
* Technically Sound<br>
* Supported by the Community<br>
<br>
The PDP can be found at:<br>
<br>
<a href="https://www.arin.net/participate/policy/pdp/" rel="noreferrer" target="_blank">https://www.arin.net/participate/policy/pdp/</a><br>
<br>
Draft Policies and Proposals under discussion can be found at: <br>
<br>
<a href="https://www.arin.net/participate/policy/drafts/" rel="noreferrer" target="_blank">https://www.arin.net/participate/policy/drafts/</a><br>
<br>
Regards,<br>
<br>
Eddie Diego<br>
Policy Analyst<br>
American Registry for Internet Numbers (ARIN)<br>
<br>
<br>
<br>
Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons<br>
<br>
Problem Statement:<br>
<br>
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.<br>
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Policy Statement:<br>
<br>
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.<br>
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Amend NRPM Section 2 to add the following definition:<br>
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2.18 Organization<br>
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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.<br>
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Comments:<br>
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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.<br>
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Staff may develop identity verification and residency requirements appropriate to individuals (e.g., government-issued photo ID and proof of address).<br>
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All resource justification, utilization, and RSA signing requirements remain unchanged.<br>
<br>
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.<br>
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Timetable for implementation:<br>
<br>
Recommend implementation within 3–6 months of ratification to allow ARIN staff and legal counsel to develop supporting processes.<br>
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Anything else:<br>
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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.<br>
<br>
<br>
<br>
<br>
<br>
_______________________________________________<br>
ARIN-PPML<br>
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</blockquote></div>