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Charging Scheme Task Force Meeting Minutes (24 February 2025)

24 February 2025

Attendees: Victor Bolaños Guerra, Sebastian Brossier, Alex de Joode, Carlos Friaças, Raymond Jetten, Ulf Kieber, Pavel Odintsov, Clara Wade

Apologies: Alexandru Doszlop, Athina Fragkouli, Ivaylo Josifov, Cynthia Revström, Alptekin Sünnetci, Piotr Strzyżewski

Chairs: Ondřej Filip, Peter Hessler

RIPE NCC staff: Fergal Cunningham, Simon-Jan Haytink, Karla Liddle-White, Marco Schmidt

1. Welcome

Executive Board Chair, Ondřej Filip, welcomed everyone and went through the agenda. He noted that the agenda had been circulated before the meeting.

2. Review of Draft CSTF Report amendments

Head of Membership Engagement, Fergal Cunningham, presented amendments to the Draft Charging Scheme Task Force (CSTF) Report to the group. He outlined the changes made in the text, which included contributions from both task force members and RIPE NCC staff.

Key revisions included an amendment to the principle that members pay the majority of their fees to be part of the RIPE NCC, allowing for additional charges on specific services. The amendments also addressed tax-related complications and the need for a review associated with charging for legacy space services.

Registration Services Manager, Marco Schmidt, presented statistics and data on registry update requests for 2024, focusing on distinct update requests and policy transfers by type within the service region. 90% of policy transfer requests included IPv4. Regarding IPv4 policy transfers by size, /24s were the most frequently transferred blocks.

One participant suggested including inter-RIR transfers and legacy resources in the data, which would provide more scope to the work and the overall workload. Marco agreed to supply this data. It was also proposed that Marco present this information to the membership at the General Meeting/RIPE 90 in May, highlighting the value of members hearing the statistics and data from the RIPE NCC directly.

Another participant thanked Marco for the data and the explanations provided. Based on the data, they raised the possibility of splitting fees based on the size of transfer—distinguishing between transfers above and below a certain threshold—to simplify the fee structure.

4. Transfers

Ondřej opened the discussion on transfer fees, noting that the membership fee must cover the majority of services provided and reminded the task force of the points made in the previous meeting on the cost implications of resource transfers and the potential for equitable fee structures.

One participant proposed a tiered structure for the seller: one fee for transfers below a /19 and a higher fee for transfers above a /19. For ASNs, they noted there was no practical way to differentiate fees based on size. Another team member added that while there was a distinction between 2-byte and 4-byte ASNs, it may not justify different fees.

For IPv6 transfers, it was proposed that there should be no differentiation between large and small allocations, though high-volume transfers could warrant further consideration. Marco noted that since the cessation of stockpiling, there haven’t been significant transfers of IPv6, so this is no longer a concern for the RIPE NCC.

There was also a suggestion to review fee structures used by other RIRs, highlighting ARIN’s approach, which includes a flat fee for the source of the transfer and a tiered fee for recipients that increased with the size of the block, aligning with the principle of keeping fees equitable for members. It was also noted that the tiered structure aggregates should be such that members do not break up transfers into smaller blocks to qualify for lower fee categories to pay less.

Another participant pointed out that RIPE operates in a unique environment due to Know Your Customer (KYC) requirements and certain restrictions. They suggested differentiating between simple and complex transfers, proposing that if a transfer incurs higher processing costs for the NCC, those costs should be passed on to the party involved. Other team members disagreed with this approach, noting that it could unfairly penalise individuals from low-income countries or economies.

Chief Financial Officer, Simon-Jan Haytink, also raised the point that the RIPE NCC should make as few subjective judgments as possible. He said that while it was reasonable to apply higher fees for complex tasks, it was crucial to ensure that all members were treated equally within the fee structure.

Marco emphasised that while some countries require additional due diligence, the RIPE NCC applies consistent sanctions checks and due diligence procedures for all transfers, regardless of the country involved. He clarified that the increased complexity often lies with the member during the process, rather than creating extra work for the RIPE NCC itself.

Marco then raised the topic of Mergers & Acquisitions (M&As), noting that while there had previously been no holding period for M&A-related transfers, such a period existed for policy transfers. He highlighted the importance of addressing cases where people seek more convenient or cost-effective transfer options and expressed support for the ongoing review of these aspects of transfers. He recommended that resource transfers via M&As should be treated the same as any other transfer, with standard fees applied to different resource types such as standard allocations, legacy resources and ASNs.

It was pointed out that some M&As, such as university mergers, occur out of necessity rather than choice. In response, a flat-rate fee for M&As was proposed that would be balanced—not too high or too low and to include a note to consider unique or complex cases, such as university mergers for further exploration. It was also mentioned that ARIN charges a flat fee of $500 to the source for M&A transfers, but unlike the tiered structure for recipients under policy transfers, there is no fee for M&A transfer recipients.

Fergal concluded the discussion by confirming he would document these recommendations.

5. Legacy Address Space

Task Force Co-Chair, Peter Hessler, led a group discussion on the handling of legacy address space, particularly in relation to fees and contracts.

One participant mentioned that if a RIPE NCC member holds legacy space, there is no additional charge, but if the legacy space holder is sponsored, the sponsoring member must pay a fee equivalent to that for Provider Independent (PI) resources (€75).

The idea of implementing a capped fee for legacy space, which increases annually, was suggested as a way to introduce a manageable administrative fee. It was noted that ARIN recently ended its discounted rates for legacy space, now charging the same fees as for regular allocations. However, ARIN previously offered discounts to legacy holders who became members, with fees increasing if they delayed joining.

Several participants agreed that the RIPE NCC Charging Scheme should encourage legacy holders to become full members. One suggestion was to charge fees for database updates, so that the database update administration fee would add up to the total suggested LRSA agreement after a low amount of updates to make it more attractive to have a formal relationship with the RIPE NCC. Though concerns were raised about the tax implications of such an approach. It was also noted that sponsored legacy holders currently receive services like RPKI, but if they became members, they would pay the standard start-up fee.

The group discussed finding an equitable way to charge legacy holders. It was suggested that an annual fee similar to that for PI resources would be fair, rather than charging the same as for standard allocations. However, concerns were raised about creating incentives that might lead to rule circumvention.

There was also debate over whether legacy holders should pay less than sponsored holders, with differing views on whether full membership should be more affordable than sponsorship. One participant argued that if a legacy holder wants the ability to assign subnets, similar to a PA block, they should be required to become a full member.

The discussion concluded with a note that specific policy decisions, such as whether legacy holders can assign subnets, fall outside the scope of this group and should be addressed within the appropriate working group.

6. Charging per Member vs Charging per LIR

Simon-Jan raised the principle of charging per member rather than charging per LIR. He presented an overview of membership and LIR account trends, noting that by the end of 2024, there were just under 20,000 members and slightly fewer than 21,000 LIR accounts, indicating that there are still approximately 1,000 multiple LIR accounts held by members.

He highlighted that the number of multiple LIR accounts increased significantly after the introduction of the IPv4 Waiting List, which required an LIR account without IPv4 to join. This led to a peak of approximately 25,300 LIR accounts.

Simon-Jan proposed that using the number of members as the base for the charging model would enhance predictability by removing the variable element of LIR accounts. The task force agreed with Simon-Jan’s assessment.

He also shared his opinion that a category-based charging model based on LIR accounts would not work effectively. There were also concerns raised about how circumventing fees or qualifying for lower categories could be easier at the LIR level than at the member level.

Simon-Jan concluded that this flexibility undermines the fairness and predictability of a category-based model tied to LIR accounts and suggested focusing on a charging structure based on membership to avoid these issues.

As the meeting time had run out, Peter proposed revisiting the discussion at the next meeting.

7. AOB

There was no other business. Peter thanked everyone for their time and concluded the meeting.