APIGA 2026 Alumni & NetMission.Asia APAC Youth Community members (see the list of contributors below) have collectively submitted to the ICANN Public Comment proceeding on the DNS Abuse Mitigation PDP 1 Initial Report, which proposes a policy framework for Associated Domain Checks (ADCs). Under the proposed framework, registrars would investigate other domains linked to a customer account or registrant when one domain has actionable evidence of DNS Abuse.
The public comment submission is summarized as followings:
Evidence, proportionality, and capacity
- Supporting ADCs when credible and sufficient evidence of DNS Abuse exists
- Applying safeguards from the point at which an ADC is triggered
- Recognizing differences in registrar size, technical capacity, and available resources
- Maintaining clear responsibility where resellers are involved
Association and external reports
- Avoiding assumptions based on a single indicator
- Clarifying how registrars should assess association between domains
- Recognizing that relevant external reports may contribute to an investigation
- Helping non-expert readers understand how these decisions may work in practice
Privacy and safeguards
- Supporting data minimization and proportionate investigations
- Reducing the risk of incorrectly associating legitimate domains with DNS Abuse
- Ensuring that proactive investigations remain evidence-driven
- Protecting the rights and interests of legitimate Registered Name Holders
Implementation, review, and records
- Keeping timelines responsive to the circumstances of each case
- Adding a 12-month implementation check-in alongside the proposed two-year review
- Using practical indicators to assess how the policy works in practice
- Allowing registrars to demonstrate compliance through proportionate records maintained in the ordinary course of business
Associated Domain Checks was the topic of Model ICANN during the Asia Pacific Internet Governance Academy (APIGA) 2026 in July, where participants each took up a stakeholder role and engaged in round table discussion to address and arrive at consensus on questions concerning the implementation of Associated Domain Check.Participants were also introduced to ICANN Public Comment process and were given an opportunity to move from learning about Internet governance to engaging with an active policy process by stepping out of their stakeholder roles and commenting with their own voices.
Following APIGA, APIGA 2026 alumni (Aviral Kaintura, Khánh Linh Nguyễn, Pali Pranjal and Vyomaa Bhaskar) and NetMission APAC Youth Community members (Iqra Ejaz, Manas Joshi, Maryam Khalid, Nawal Munir, Sana Nisar, Sawera Masood and Zainab Fayyaz Cheema) continued working together as part of the wider APAC Youth Community. During the Public Comment period, the group met to discuss the Initial Report, identify key issues, and develop its comments collectively.
Since the group of contributors did not have direct experience with the day-to-day operations of registrars and registries, they considered how the proposed policy might be understood by registrants and other readers without technical or operational experience, and foregrounded clarity and accessibility throughout their discussion.
Read their full submission at:
The list of contributors:
APIGA 2026 alumni –
- Aviral Kaintura
- Khánh Linh Nguyễn
- Pali Pranjal
- Vyomaa Bhaskar
and NetMission APAC Youth Community Members
- Iqra Ejaz
- Manas Joshi
- Maryam Khalid
- Nawal Munir
- Sana Nisar
- Sawera Masood
- Zainab Fayyaz Cheema.
Writer of this article: Manas Joshi