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This policy proposal has been accepted
The new RIPE Document is: ripe-682

RIPE Resource Transfer Policies

Summary of Proposal

The goal of this proposal is to create a single document with all relevant information regarding the transfer of Internet number resources.

Replacing all transfer-related policy text from the allocation and assignment policies and keeping this in one document will make it easier for people to find the information they are looking for. This will also make it easier to maintain the various policies in future. All of the allocation and assignment policies will include a reference to this document.

The following policy documents currently have text relating to transfers:

The final transfer document will aim to generalise the policy text as much as possible. It will explain specific restrictions or exceptions relating to the various types of Internet number resources as required

The proposal extends the 24-month transfer restriction to resources that have been transferred due to changes to an organisation’s business structure (such as a merger or acquisition). It is important to note that this restriction only prevents policy transfers – resources subject to this restriction may still be transferred due to further mergers or acquisitions within the 24-month period.

The proposal also requires that the RIPE NCC publish information about transfers due to changes to an organisation’s business structure (such as a merger or acquisition) in the same way that it already does with general transfers.

Policy Text

[The following policy will replace:

- Sections 5.5 and 6.4 in ripe-649, "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region"
- Section 4.0 in ripe-638, "Autonomous System (AS) Number Assignment Policies"
- Section 8. in ripe-655, "IPv6 Address Allocation and Assignment Policy"

The text in these sections will be replaced by a reference to the new RIPE Document, "RIPE Resource Transfer Policies"

- ripe-644, "Policy for Inter-RIR Transfers of Internet Resources"

This policy document will be deleted.]

Content

1.0 Scope
2.0 Transfers within the RIPE NCC Service Region
2.1 Transfer Requirements
2.2 Transfer Restrictions
3.0 Inter-RIR Transfers
3.1 General
3.2 Transferring Internet Number Resources to the RIPE NCC Service Region
3.3 Transferring Internet Number Resources from the RIPE NCC Service Region
4.0 Transfer Statistics
5.0 Attribution

 

1.0 Scope

This policy outlines:

  • The rules for Internet number resource transfers within the RIPE NCC service region
  • The rules for Internet number resource transfers (including legacy resources) to and from the RIPE NCC service region (often referred to as inter-RIR transfers)


2.0 Transfers within the RIPE NCC Service Region

Any legitimate resource holder is allowed to transfer complete or partial blocks of address space or number resources (IPv4, IPv6 and AS Numbers) that were previously allocated or assigned to them by the RIPE NCC or otherwise through the Regional Internet Registry (RIR) system. Resources are excluded from transfers when RIPE Policies mandate their return to the RIPE NCC.

Allocated resources may only be transferred to another RIPE NCC member. Provider independent resources may be transferred to:

 

2.1 Transfer Requirements

Transfers must be reflected in the RIPE Database. Transfers can be on a permanent or non-permanent basis.

The original resource holder remains responsible for an Internet number resource until the transfer to the receiving party is completed. In the case of a temporary transfer, the original resource holder re-assumes responsibility when the resource is returned. The current resource holder must ensure that all relevant policies are applied.

Transferred resources are no different from allocations or assignments made directly by the RIPE NCC and so must be used by the receiving party in accordance with the respective policy documents.

To complete the transfer, the RIPE NCC will update the registration records of the Internet number resource to reflect the transfer.

 

2.2 Transfer Restrictions

Scarce resources, which are understood as those resources that are allocated or assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit ASNs), cannot be transferred for 24 months from the date the resource was received by the resource holder. This restriction also applies if the resource was received due to a change in the organisation’s business (such as a merger or acquisition).

This restriction does not prevent the resources from being transferred due to further mergers or acquisitions within the 24-month period.

 

3.0 Inter-RIR Transfers


3.1 General

Any type of Internet number resource can be transferred to or from the RIPE NCC service region. This includes legacy resources, in spite of the fact there are no specific rules for legacy resource transfers within the RIPE NCC service region.

Resources are excluded from transfers when RIPE Policies mandate their return to the RIPE NCC.

RIPE Policies will apply while the transfer is in process, for as long as the Internet number resources are registered within the RIPE NCC service region.

 

3.2 Transferring Internet Number Resources to the RIPE NCC Service Region

The RIPE NCC shall accept all transfers of Internet number resources to its service region, provided they comply with the policies relating to transfers within its service region.

For transfers from RIR service regions that require the receiving region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of at least 50% of the transferred resources within five years.

 

3.3 Transferring Internet Number Resources from the RIPE NCC Service Region

When transferring Internet number resources to another RIR, the RIPE NCC will follow the transfer policies that apply within its own service region. The RIPE NCC will also comply with any commitments imposed by the receiving RIR in order to facilitate the transfer.

 

4.0 Transfer Statistics

The RIPE NCC will publish a list of all transfers. This publication shall occur on monthly basis or more frequently if the RIPE NCC so chooses.

This list will contain information about approved changes. The following information will be published:

  • The name of the offering party
  • The resource originally held by the offering party
  • The name(s) of the receiving party or parties
  • Each subdivided prefix (each partial block derived from that original block) or resource received
  • The date each resource was transferred
  • Whether it was a transfer according to this policy or a transfer due to changes to an organisation's business structure (such as a merger or acquisition)
 

5.0 Attribution

This document is developed by the RIPE community.

The following people actively contributed by making proposals through the RIPE Policy Development Process:

Erik Bais

Rationale

a. Arguments supporting the proposal

  • The goal of this proposal is to reduce the amount of documents where various parts of a transfer policy can be found, based on the type of number resource. When the initial transfer policies were written, it was already intended to move the new policy text to a dedicated transfer policy document.
  • To improve transparency, the transfer statistics now include insight into all transfers, including mergers and acquisitions.

b. Arguments opposing the proposal

  • The document implements a couple of slight wording changes into the documents to make the writing more generic.
  • The document proposes to apply the transfer restrictions to mergers and acquisitions. This is done to make the policy more in line with the intention of the transfer policy restrictions when proposed.

Impact Analysis

Note: In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication of the possible impact that the policy might have if the proposal is accepted and implemented.

A. RIPE NCC's Understanding of the Proposed Policy

It is the RIPE NCC’s understanding that this proposal will replace all transfer-related text in the various resource policy documents (for IPv4 Provider Aggregatable (PA) and Provider Independent (PI), IPv6 PA and PI, Autonomous System (AS) Numbers) and combine this into one document. The text of the transfer sections in the various resource policy documents will be replaced with references to the new policy document “RIPE Resource Transfer Policies”.

The document “Policy for Inter-RIR Transfers of Internet Resources” will be replaced completely by the new policy document.

Most of the requirements for transfers will remain the same as they are in the current transfer policies, as will the related procedures.

This analysis will focus on the changes that this proposal introduces.

Entities That Can Receive a Transfer

The proposed policy says:
“Allocated resources may only be transferred to another RIPE NCC member. Provider Independent resources may be transferred to:

  • A RIPE NCC member; or
  • An entity that has a contractual relationship with a RIPE NCC member

in accordance with the RIPE Policy, “Contractual Requirements for Provider Independent Resource Holders in the RIPE NCC Service Region”.

It is the RIPE NCC’s understanding that allocations of IPv4 and IPv6 can only be transferred to organisations that are members of the RIPE NCC (i.e. have a Local Internet Registry (LIR) account). Independent resources (such as IPv4 PI, IPv6 PI and AS Numbers) can be transferred to organisations that are members of the RIPE NCC or have a contractual relationship with a sponsoring LIR as per RIPE Policy, “Contractual Requirements for Provider Independent Resource Holders in the RIPE NCC Service Region”.

Resources Excluded from Transfers

The proposed policy change excludes resources that are required to be returned to the RIPE NCC by the policies governing their issue. Currently this would apply to the following resources:

  • IPv4 Internet Exchange Point (IXP) - "This space will be used to run an IXP peering LAN; other uses are forbidden. [...] New IXPs will be assigned a /24. Should they require a larger assignment, they must return their current assignment (or existing PI used as an IXP peering LAN) ..."
    IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region - Section 6.1
    While the policy specifies the return requirement for the situation where an IXP needs a larger assignment, it is the RIPE NCC's established understanding that this requirement also applies to situations where the IXP is not in need of the assignment anymore.
  • IPv6 Anycast - "Anycasting assignments are registered with a status of 'ASSIGNED ANYCAST' in the RIPE Database and must be returned to the RIPE NCC if not in use for infrastructure providing authoritative TLD or ENUM Tier 0/1 DNS lookup services any longer."
    IPv6 Address Allocation and Assignment Policy - Section 6
  • IPv6 for Internet Root Servers - "If a root server stops operating within the RIPE region, the address space will be returned to the RIPE NCC and marked as "reserved" for a suitably long period of time." 
    IPv6 Addresses for Internet Root Servers in the RIPE Region
  • Temporary Assignments - "The RIPE NCC may assign number resources to End Users on a temporary deployment basis for a specific time-limited purpose. [...] The number resources will be automatically de-registered and returned to the appropriate reservation pool at the end of the approved assignment period."
    Temporary Internet Number Assignment Policies - Section 2.1

N.B. IPv6 IXP assignments are not excluded from transfer because the associated policy does not specify a return requirement. The receiving party would, however, need to meet the policy requirements defined in the IPv6 Address Space Policy For Internet Exchange Points Points (https://www.ripe.net/publications/docs/ripe-451) before the transfer could be completed. If this is not the intention of the community it may be necessary to make some policy development to ripe-451.  

If a policy change removes or adds a return requirement for an Internet resource, the list of resources excluded from transfers will be adjusted accordingly.
The RIPE community is currently discussing the policy proposal 2016-03, "Locking Down the Final /8 Policy". If this proposal reaches consensus in the current version, all IPv4 allocations provided by the RIPE NCC after 14 September 2012 would be excluded from transfers.

Holding Period for Scarce Resources

The proposed policy in its latest version says:
“Scarce resources, which are understood as those resources that are allocated or assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit ASNs), cannot be transferred for 24 months from the date the resource was received by the resource holder. This restriction also applies if the resource was received due to a change in the organisation’s business (such as a merger or acquisition). This restriction does not prevent the resources from changing holdership due to further merger or acquisition within the 24-month period.”

The RIPE NCC understands “scarce resources” to include IPv4 PA, IPv4 PI and 16-bit AS Numbers. If the community declares other resources to be scarce, the list of resources for which the holding period will apply will be adjusted accordingly.  

The proposal introduces a 24-month holding period from the moment an Internet resource has been registered by the RIPE NCC to a resource holder. Within this period, it will not be possible to transfer the resource under RIPE Policies.

Company mergers and network acquisitions that include Internet resources are possible at any time as they are not regulated by RIPE Policies. The proposed policy text underlines this.

The holding period of 24 months will start from the moment the RIPE NCC registers the resource to the holder in the RIPE Database. This applies whether the resource was received:
- Directly from the RIPE NCC
- Via a policy transfer
- Through an organisation merger, acquisition, bankruptcy or liquidation

Holdership changes during a temporary resource transfer will not re-start the 24-month holding period for the original resource holder. While in a strict sense the return of the resource to the original holder could be seen as “receiving back”, the Address Policy Working Group decided during RIPE 69 that the 24-month holding period should not apply to such temporary holdership changes
The temporary resource holder will not be able to transfer the resource further during the period in which the resource is registered to them.

Any other change to an Internet resource that is not related to a holdership change (for example, a company name change or converting address space to another resource type) has no influence on the holding period.

Publishing Transfer Statistics

The proposal extends the publication of transfer-related information to include transfers completed as a result of mergers and acquisitions. This information would only be published for mergers and acquisitions completed after the implementation of the policy, not for those approved previously.

The proposed policy change excludes the publication of aggregate statistics for non-approved holdership changes. Since the adoption of the policy proposal 2013-03, “Post Depletion Adjustment of Procedures to Match Policy Objectives, and Clean-up of Obsolete Policy Text”, the RIPE NCC no longer performs needs-based evaluation of transfers. Publication of statistics for non-approved IPv4 transfer requests is therefore no longer relevant.  

There is an important distinction between “non-approved” requests and “invalid/incomplete” requests. If a request is received which cannot be completed due to a policy restriction (for example IPv6 allocations smaller than the minimum /32 or IPv4 allocations which have already changed holdership within the previous 24 months), it is considered to be invalid. If a request is received with inadequate supporting documentation (for example missing the signed transfer agreement), it is considered to be incomplete. In both of these scenarios, the RIPE NCC is unable to complete the evaluation of the request and therefore it cannot be considered to be either approved or non-approved.  

B. Impact of Policy on Registry and Addressing System

Address/Internet Number Resource Consumption:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

Fragmentation/Aggregation:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

Software Engineering:
Software development will be needed to:

  • Update the transfer statistics to differentiate between policy transfers and mergers/acquisitions
  • Prevent transfer of scarce resources for 24 months after any ownership change

Registration Services:
Some manual intervention will be required from Registration Services to support Software Engineering with identifying and excluding LIR account consolidations from the existing list of mergers/acquisitions.

External Relations:
This proposal continues a trend towards defining policies according to the action being performed (in this case the transfer of resources between holders), rather than according to the type of resource (such as a policy for allocation and assignment of IPv6 address space). The community has identified this approach as producing more straightforward policy, and the RIPE NCC agrees with this assessment. In the short term it is expected that we need to increase outreach to raise awareness of these changes within the broader Internet community.

Billing/Finance Department:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

RIPE Database:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

D. Legal Impact of Policy

If this proposal becomes policy, the RIPE NCC may need to update the relevant procedural documents, including the RIPE NCC procedural document “Transfer of Internet Number Resources and Change of a Member’s Official Legal Name”.

E. Implementation

With the information currently available, it is expected that implementation of the proposal would have a medium impact in terms of the software development needed to facilitate the policy changes in internal RIPE NCC systems. Internal and external processes and documentation would also need to be updated.

Get Involved

The Address Policy Working Group develops policies relating to the allocation and registration of Internet number resources (IPv4 and IPv6 addresses and ASNs) by the RIPE NCC and its members. Anyone with an interest in Internet numbering issues is welcome to observe, participate and contribute to the WG. To post a message to the list, send an email to address-policy-wg@ripe.net. Please note that only subscribers can post messages.

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