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

Thu Oct 8 11:43:15 UTC 2026

Hi Mphoentle,

See below, in-line.

Regards,
Jordi

@jordipalet

> El 5 oct 2026, a las 11:29, Mphoentle Mokheseng <ST10120874 at vcconnect.edu.za> escribió:
> 
> Hi Jordi,
>  
> Thank you for the answer. I understand the sequence you describe, and I am not asking the proposal to reproduce the RSA or the transfers policy. My question is narrower, and your reply makes it sharper rather than closing it.
> 
> You say transfers can only be made if the resources and the holder are "in good standing", and that the transfers section is being replaced by the newer transfers policy once implemented. "Good standing" does not appear anywhere in this proposal. So, the interaction between a dashboard record and transfer eligibility is governed by an instrument this proposal does not mention and does not coordinate with. That is the gap: a member can now be monitored, notified, recorded, and alerted to staff on a "possible" non-compliance, and nothing in the text says whether that record is an input to "good standing".
> 

The transfers policy, already ratified and under implementation, say (https://afrinic.net/afpub-2020-gen-006-draft03#Proposal): “The source holder must be the rightful holder of the resources being the subject of the transfer and that the resources must not be the subject of any dispute, known or contemplated.”

For me that means “good standing”. It may be a translation issue if the meaning is different for several of us?

> You also say the proposal "doesn't have text for enforcing the recovery or closure", that the appendix is not policy text, and that this depends on staff or board decisions already taken and not changed by this proposal. I have two difficulties with that.

The PDP states that the normative text is section 3.

I think the rest of your points have just been responded to in the previous emails, so I’m not repeating them.

> 
> First, item 4 of the normative text does contemplate the consequence: AFRINIC "is able to initiate a more exhaustive investigation and take further actions (such as service withholding, revocation or even member closure)", when there is "evidence suggesting that there is lack of compliance". The consequence is therefore stated in the policy, while everything about an orderly exit is not: how a pending transfer is handled before recovery, whether the records needed to complete it remain accessible, and whether an unresolved dashboard item affects eligibility. A member can be taken down the consequence path with no policy-stated route out, even where nobody disputes the holder's control. The only transfer reference in the whole proposal is the appendix example about "unauthorized transfers".
> 
> Second, "not changed by this proposal" is difficult to reconcile with items 2 to 4. The proposal adds a monitoring duty, a notification duty to members and staff on a possible finding with previous history, and a verification step. Even if the consequence thresholds are unchanged, what precedes them is not: there is now an automated record and a staff alert that did not exist before. A new input into an unchanged decision is still a change in outcome, and it is the kind of change the earlier impact assessment described when it warned about staff discretion.
> 
> Three questions:
> 
> 1. Which instrument defines "good standing" for transfers, and does a dashboard "possible" finding — or an unresolved dashboard item — count against it? If it does not, please say so in the proposal text.
> 
> 2. The transfers section is being replaced "once implemented". The dashboard would take effect before that. Will the dashboard record be an input to the replacement transfer policy, and will it remain part of the member's record across the change?
> 
> 3. If the appendix is not policy text, what governs recovery and closure in the interval — the staff procedures in force today, unmodified? If so, the community should be told which published procedure that is, and that this proposal adds nothing to it.
> 
> Changes I would support:
> 
> - A normative statement that a dashboard indication, whether possible or confirmed, does not by itself constitute a dispute concerning the status of the resources, and does not by itself make a holder not in good standing for the purposes of a transfer.
> - A defined period before any recovery or closure step in which an otherwise eligible transfer may proceed, and during which the registry records needed to complete it remain accessible.
> - An express statement that compliance matters under this proposal do not alter transfer eligibility under CPM 5.7 except as the applicable transfer policy expressly provides.
> 
> If your intent is that nothing about recovery, closure or transfer eligibility changes, that belongs in the policy text, not only in an email. One sentence would remove the uncertainty.
> 
> I am not claiming the proposal removes a transfer right, and I am not asking it to restate the RSA. I am asking it not to state the consequence while leaving the exit route undefined, and I oppose the proposal as drafted until that is resolved.
> 
> BR,
> Mphoentle
> 
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