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

[NPC SVG]

Like Abbas and Julf , I also believe the use of the term DNS abuse broadens
the indicator into an area unsuitable for the GNSO council for reasons
described below.

RD

On Mon, Jun 15, 2026, 3:08 PM <
0000222a86a53d44-dmarc-request at listserv.syr.edu> wrote:

> Julf, I agree with the analysis by Abbas. Explicitly Including “DNS abuse”
> broadens the indicator into an area unsuitable for the GNSO Council for the
> reasons he describes.
>
>
>
> In terms of a statement, we can perhaps relate something like “the ICANN
> community has reached general consensus around a narrow set of DNS security
> threats (phishing, malware, botnets, pharming, and spam as a delivery
> mechanism). However, there has not been universal stakeholder consensus on
> the broader conceptual definition of DNS Abuse or on where the boundary
> lies between DNS abuse and content abuse. Therefore, since the term DNS
> abuse” can mean different things to different stakeholders, even within the
> narrow threats mentioned, by including "DNS abuse" as an indicator for
> evaluating the performance of the GNSO council risks creating unclear, and
> potentially unrealistic, expectations for achieving the stated criteria, to
> say nothing of the opportunity for debate regarding whether or not the
> criteria has been met.”
>
>
>
> I hope this helps.
>
>
>
> Ken
>
>
>
> *From:* NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU> *On Behalf Of *Abbas
> Sibai
> *Sent:* Monday, June 15, 2026 9:33 AM
> *To:* NCSG-DISCUSS at LISTSERV.SYR.EDU
> *Subject:* Re: SCCI Criteria 4 - “domain name security threats”
>
>
>
> 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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