[rpd] Updated Proposal - AfriNIC Policy Compliance Dashboard AFPUB-2026-GEN-002-DRAFT02

[Mphoentle Mokheseng]

Dear Co-Chairs and colleagues,

A further concern is how a member can complete an orderly transfer before membership closure or resource recovery. DRAFT02’s illustrative recovery sequence provides an opportunity to regularise the situation but does not explain how an otherwise permissible transfer to an eligible recipient would be handled during that period. This leaves an important alternative to recovery unaddressed.

There is a specific interaction with the published CPM that needs clarification. Section 5.7.3.1 requires the transfer source to be the recognised rights holder and not be involved in a dispute concerning the status of the resources. That makes the distinction between a disagreement about an administrative obligation and a dispute about entitlement to the resources particularly important.

DRAFT02 does not explain whether a dashboard compliance case could affect that transfer eligibility. My concern is that, without an explicit distinction, an administrative disagreement could be treated as a resource-status dispute and prevent a transfer even where nobody contests the holder’s control. This is a potential interaction requiring clarification, not a claim that the draft expressly prohibits transfers.

Consider a member winding down its business and arranging an otherwise eligible transfer to another network. The relevant question should be whether that transfer can be authenticated and accurately recorded, rather than whether the outgoing organisation must continue its existing membership indefinitely. Ending a service relationship and surrendering resources should not be treated as the same event. This reflects the principle that portability and the ability to export registry records should support operator independence.

The proposal should therefore explain how pending transfers are handled before recovery, preserve access to the records needed to complete them, and establish a defined transition period for an otherwise eligible transfer. A dashboard case should not, by itself, become an additional transfer restriction. Any broader right to move registry administration elsewhere would require its own clearly specified arrangements; it should not be assumed to exist already.

This would not excuse fraud, override a binding legal restriction, or remove outstanding obligations owed by the outgoing member. It would distinguish those obligations from the separate question of whether a verified change of holder can proceed. That separation is consistent with a registry function centred on recording legitimate changes of control rather than making exit dependent on continued institutional approval.

An orderly transfer should be an expressly addressed outcome, not an option left uncertain until a member is already facing recovery.

BR,
Mphoentle
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