[Ncsg-discuss] SCCI Criteria 4 - “domain name security threats”

[Abbas Sibai]

Hi Julf,

Thanks for flagging this. As an individual member of the NCUC, I completely
share your concerns. Specifically inserting the term "DNS Abuse" into the
GNSO Continuous Improvement Program framework is a major red flag that we
definitely need to push back against during the upcoming call on Wednesday,
1 July 2026.

>From our constituency’s perspective, my understanding is that there are two
distinct "cans of worms" this proposal opens up:

   -

   *Mission Creep and Content Regulation:* Broadening the text to
   explicitly name "DNS Abuse" risks shifting the GNSO's focus from core
   technical layer infrastructure toward content regulation. What I
   understood is that the NCUC has a long-standing commitment to fiercely
   protecting freedom of expression and digital rights. If the indicators
   explicitly target "DNS Abuse" rather than strictly defined security
   threats, it invites outside pressure on the GNSO to police website content
   , a precedent that directly undermines our core mission and human rights
   principles.
   -

   *Disproportionality and Human Rights Impacts:* I also understood that
   NCUC has consistently advocated that any policy intervention addressing
   domain security must be narrow, proportionate, and strictly scoped. Tying
   the evaluation of the GNSO's performance to broad and subjective
   perceptions of "DNS Abuse" (especially via a survey indicator) creates an
   incentive to pass sweeping, reactive policies. This places innocent
   registrants at risk of collective or automated domain suspensions without
   adequate due process or Human Rights Impact Assessments (HRIAs).

The original text, focusing strictly on "mitigating domain name security
threats," keeps the evaluation grounded within the GNSO's technical and
contractual scope. The proposed revision unnecessarily complicates it and
opens the door to over-policing at the registry/registrar level.

I fully support our leadership taking a strong stance against this text on
Wednesday. Please let me know if you need any assistance with drafting a
formal statement or if there are specific points you want supported during
the call.

Warm Regards,
Abbas Sibai
Policy & Advocacy Specialist
+9613824725
| https://www.linkedin.com/in/abbas-sibai/



On Mon, Jun 15, 2026 at 12:28 PM Johan Helsingius <
00001963cc94b85a-dmarc-request at listserv.syr.edu> wrote:

> Hi all,
>
> I am the NCSG representative to the Standing Committee on Continuous
> Improvement (SCCI) that is formulating the Continuous Improvement
> Program framework. The SCCI is chaired by Manju, another NCSG:er, but
> as chair she has to remain neutral.
>
> The work until now has been developing the Criteria and Indicators
> that will be used to judge how well the GNSO processes are working.
>
> We have made good progress under the very capable leadership of Manju,
> and most issues haven't been very controversial, but I want to flag
> the current issue where we probably want to speak up against the current
> proposal.
>
> The issue is Criteria 4, "The GNSO actively combats domain name
> security threats", where there is a proposal to change the draft
> text from:
>
>      Indicator 1: The GNSO has demonstrated meaningful activity towards
>                   mitigating domain name security threats.
>
>      Indicator 2:  66% of surveyed respondents agree that the GNSO
>                    combats domain name security threats.
>
> to:
>
>      Indicator 1: The GNSO has demonstrated meaningful activity towards
>                   mitigating DNS Abuse and security threats relating to
>                   domain names that are in scope for the GNSO.
>
>
>      Indicator 2:  66% of surveyed respondents agree that the GNSO has
>                    demonstrated meaningful activity towards mitigating
>                    DNS Abuse and security threats relating to domain
>                    names that are in scope for the GNSO.
>
> While we probably are OK with mitigating domain name security threats,
> specifically mentioning DNS Abuse opens up some cans of worms.
>
> We will have a chance to present our views at the next SCCI call on
> Wednesday, 1 July 2026, so I welcome your comments/opinions.
>
>         Julf
>
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