Ukraine’s representative to ICANN’s Governmental Advisory Committee (GAC) has sent a letter to the Internet Corporation for Assigned Names and Numbers (ICANN) to remove Russian-administered top level domains (.RU, .SU and .рф) from the DNS root zone. In a separate letter, Ukraine’s representative also asked RIPE NCC to withdraw the right to use all IPv4 and IPv6 addresses by all Russian members of the regional IP registry for the European region.

Despite our strong opposition to Russia’s war, and our support for punitive sanctions targeting Russia’s capacity to sustain military operations economically, this proposal is misguided and dangerous. It strikes at the very basis of the neutral administration of naming and numbering registries that is required to make global communications fair and accessible to everyone. The whole point of ICANN’s creation was to distance Internet infrastructure administration from nation-states and their geopolitical conflicts. Heeding these requests would destroy the independence and accountability of the Internet governance institutions. And informational isolation of Russia would in many ways further Putin’s agenda, by cutting off Russian citizens and businesses from independent sources of information.

Institutional suicide

Here’s the most fundamental  problem with the request. The call for unilateral action by ICANN Org is also a call to ignore the global Internet community’s policy making and accountability structures. ICANN’s complex representational and participation mechanisms were created to make its policy decisions deliberate, responsive, follow known procedures and be constrained by ICANN’s bylaws. This was based on a recognition that technical authority over Internet identifier assignment could be abused to pursue unrelated aims, ranging from censorship to copyright enforcement to geopolitics. The purported human rights advocates who are calling for emotional and quick actions are opening the door to all kinds of future interventions they surely would not like. In the real world, the protection of human rights requires due process, representation and limitations on arbitrary power. That is why the bylaws define ICANN’s mission and scope narrowly.

Asking the IANA (PTI) to suddenly yank entries in the root registry because of a geopolitical dispute would literally destroy the organization’s policy development and accountability processes. The people making this request don’t seem to be considering who would make this decision? Nabok’s letter is addressed to ICANN’s CEO and the manager of the IANA, as if those two had the authority to act unilaterally. They don’t – or if they do, or are ordered to (by who?), ICANN’s community policy development process is dead.

One commentator has raised the question whether the delegation of the .RU, .SU and .рф ccTLDs could be challenged based on Russia’s actions. That is, could authority over the .RU domain be delegated to a new owner based on the regular misuse of it by the Russian state? This may or may not be possible, but it is a much better way to approach the problem. ICANN’s Country Code Names Supporting Organization sets policies in this area.  Existing policies on redelegation would probably have to be modified to apply to this situation. Many ccTLD operators might balk at redelegation criteria that could in the future threaten themselves. And this is precisely why we have institutional mechanisms for making these decisions. We need carefully defined policies that take into account stakeholder views and possible misuses or unintended consequences of any policy changes. Current calls for instantly bending the entire Internet governance regime to momentary outrage about Russia are more about posturing than effective responses to Russian aggression. These efforts to appear virtuous in opposition to a clear evil can inadvertently do long term damage to human rights.


According to the Ukrainian GAC representative’s letter, “these atrocious crimes [Russia’s military invasion] have been made possible mainly due to the Russian propaganda machinery using websites continuously spreading disinformation, hate speech, promoting violence and hiding the truth regarding the war in Ukraine.” Aside from the fact that he is calling upon the use of ICANN to regulate speech, which is against its bylaws, that claim seems obviously false. Russia’s military invasion was not “made possible” by propaganda, disinformation or “hate speech.” It was made possible by Putin’s long standing desire to make Eastern European states subordinate buffer zones against NATO. and by amassing troops, armor and weapons on the border. Due in large part to widespread internet-based communications, Russia has lost the propaganda war: no one is buying its excuses for the invasion. Ukrainians themselves are obviously not fooled by Russian claims that they should be part of Russia. The rest of the world is rejecting Putin’s narrative. There are even protests in Russia. A complete disconnection of Russia from the Internet hurts many innocent people. Putin’s efforts at propaganda and disinformation are better countered by targeting the government’s mouthpieces. And this is what numerous social media platform operators have already done.

The letter also claims that a cutoff is necessary because “Ukrainian IT infrastructure has undergone numerous attacks from the Russian side impeding citizens’ and government’s ability to communicate.” This is true, but Ukrainian networks themselves can block specific Russian ASNs, IP addresses and domains if they think it is warranted. That’s the beauty of Internet’s distributed governance model: each network operator can institute their own responses, decide for themselves what to block and what to let in. Action by ICANN to globally disable all Russian domain names, network numbers and IP addresses is a disproportionate response. At any rate, the real battle now is a military one, not an information operation. Sanctions from the West are only relevant insofar as they degrade Moscow’s military strength and/or undermine its ability to economically sustain the action. Ruining global Internet governance won’t make a difference.


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