ICANN clarifies registrar obligations for domain contact web forms

The Internet Corporation for Assigned Names and Numbers has published an advisory clarifying how accredited domain registrars should implement web forms within Registration Data Directory Services (RDDS).

The issue concerns how third parties can contact domain name registrants after changes introduced under ICANN’s Registration Data Policy, which took effect in August 2025.

Under the policy, registrars may replace publicly displayed email addresses with either pseudonymised email addresses or web forms. The change was introduced partly to align registration data practices with global privacy and data protection requirements.

Questions emerged after at least one registrar implemented a web form that only generated an automated notification informing a registrant that someone was attempting to make contact. The system reportedly did not allow users to send their own message text or attachments directly through the form.

Some members of the ICANN community argued that such systems may not satisfy the requirement to “facilitate communication” between third parties and registrants.

The new advisory explains how ICANN interprets current compliance obligations and under what circumstances web forms will be considered acceptable under RDDS requirements.

The dispute reflects a broader redesign of domain registration data systems following privacy reforms such as the EU’s GDPR. Over recent years, registrars and policymakers have struggled to balance personal data protection with operational needs linked to cybersecurity, abuse reporting, intellectual property disputes, and technical coordination.

At the centre of the debate is a practical question: whether contact systems that merely notify registrants about communication attempts are functionally equivalent to direct email-based communication mechanisms traditionally used in domain registration databases.