ICANN opens public consultation on updated Trademark Clearinghouse requirements
ICANN is seeking community feedback on revised Trademark Clearinghouse Requirements, which introduce updates tied to the next expansion of the gTLD space and implement key rights-protection recommendations from earlier policy work.
The Internet Corporation for Assigned Names and Numbers has launched a public comment period on proposed updates to the Trademark Clearinghouse Rights Protection Mechanism Requirements (TMCH Requirements). The consultation runs from 18 December 2025 to 27 January 2026 and will help shape how trademark protections function in the next round of new generic top-level domains.
The TMCH Requirements set out the obligations for registry operators during Sunrise and Trademark Claims periods. ICANN is proposing several revisions, including the implementation of Sunrise Final Recommendation #8 from the first phase of the Rights Protection Mechanisms Policy Development Process. The proposed changes clarify that challenges to Sunrise registrations based on trademark record validity should be handled through the TMCH’s own dispute procedure, rather than by registry operators, who must instead suspend a domain name to allow such challenges to proceed.
Other updates align the TMCH Requirements with the 2026 Base Registry Agreement, including changes in terminology, refreshed documentation links, and the integration of materials previously kept in addenda. ICANN proposes that these revised requirements apply not only to new registry operators in the 2026 round but also to existing operators from the 2012 round, citing minimal operational impact and the need for consistency across the gTLD space.
The changes also affect registrars, who would be required to deliver Claims Notices in the same language as the registration agreement, provide time-stamped acceptance details, and use the updated notice language. Registry operators would need to follow new rules for Qualified Launch Programs and ensure Trademark Claims Service data is current.
ICANN is inviting community input through a guided submission form, with redlined and clean versions of the proposed TMCH Requirements available for review. Once the consultation closes, ICANN will publish a summary report and determine whether further revisions are required.
