Important: DNS Abuse Small Group

[farzaneh badii]

Dear Members,

As I mentioned before the Council has a small team on DNS abuse and we need
to write up an issue report. At the moment we are working on the gaps here:
https://docs.google.com/spreadsheets/d/1TRyUYb4Dr1VqxJ1H9n983ClbGx968QK0/edit?gid=1836517289#gid=1836517289
The small team members should consult with their stakeholder groups. So I
am consulting with you, here are the concerns I see in the solutions and
going to send a few of the concerns to the small team after your
consideration. Please weigh in by next week:


Principles for Rights-Respecting DNS Abuse Mitigation

Associated Domains & Surveillance
When investigating actionable DNS abuse, registrars may need to examine
other domains associated with the same registrant data to disrupt broader
abuse networks. However, such inspections must be conducted with strict
safeguards to avoid undue surveillance of legitimate registrants.
Investigations must be grounded in clear, specific evidence of abuse linked
to the registrant—never on speculative or broad profiling. The focus must
remain on the abusive activity, not on surveilling the registrant’s broader
online presence.

Domain Pricing & Access
Affordable or free domain names are essential for digital inclusion. They
allow individuals, small businesses, and civil society groups to establish
a presence online.

   -

   Pricing should not be used as a blunt tool for abuse mitigation. Doing
   so risks disproportionately harming legitimate users and undermining
   efforts to expand equitable access to the Internet.
   -

   Abuse mitigation by registrars offering low-cost domains should instead
   rely on rights-respecting measures: clear abuse reporting channels, prompt
   investigation, proportionate response, and strong due process—not financial
   barriers.

Reactive vs. Proactive Measures
Well-implemented reactive measures can be as effective as proactive
strategies in addressing abuse.

   -

   However, overly broad or premature proactive interventions (e.g.,
   preemptive takedowns, automated flagging) can generate false positives,
   unjust suspensions, and chilling effects on lawful expression.
   -

   Any proactive measure must be subject to rigorous human rights risk
   assessment, implemented with narrowly tailored scope, transparency, and
   meaningful recourse options to ensure proportionality and accountability.

Pre-Mitigation Due Diligence
Before taking any mitigation action, registrars must carry out thorough and
proportionate due diligence based on specific, actionable evidence. This
helps prevent false positives and ensures that mitigation measures are
appropriate to the verified abuse. Where possible, less restrictive
alternatives should be considered before resorting to domain suspension.

During Mitigation Transparency
When action is taken against a domain, the registrant must be promptly
notified. This notice should include:

   -

   The reason for the action;
   -

   The type of action taken;
   -

   The initiator of the action (e.g., registrar, third-party request);
   -

   A clear explanation in accessible language.

Post-Mitigation Remedy & Recourse
Registrars must maintain accessible and transparent mechanisms for
registrants to seek remedy or challenge decisions. This includes:


   -

   Restoration Process: A pathway for legitimate registrants to demonstrate
   that abuse has been resolved—or that the action was mistaken—and regain
   control of their domain in a timely manner.
   -

   Complaints & Appeals: A clear and fair process through which registrants
   can file complaints or appeal mitigation actions, reinforcing procedural
   fairness and accountability.


Farzaneh
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