Hi Sunny, all,

As discussed today, the public log change was not intended, however, it seems to make sense to keep that text in order to ensure that the public log is for all the transfers. Doesn't make any sense to “hide” some of them from the log.

Just in case, the community doesn’t agree with that, we can make a two consensus calls, one for the unification of all the transfer policies, and another one to make the log for all the transfers or only for the ones as per current section 8.1/8.2.

This way, we don’t need a new version and unless the community strongly disagree, the log will be extended to all the transfers, as it should be.

We shall notice that the lack of that “complete” log, was probably not intended by the authors of the other transfer policies and having it is part of the expected transparency of all RIRs operations.

So, it will be good if anyone disagree or find any reasons this log should not include all the transfers, to state it ASAP.

Tks!

Dear SIG members,

Here is the Secretariat impact assessment for prop-142-v001.

APNIC understands this proposal is suggesting combining the individual resource type (IPv4, IPv6, ASN) transfer policies under a new part (Part 5) of the APNIC's Internet Number Resource Policies document.

APNIC also notes that this proposal is NOT intending to amend the current transfer policies. However, currently APNIC maintains a public log of intra and inter-RIR IPv4 transfers only made under Sections 8.1 and 8.2. The proposed policy is suggesting changing this to maintain a public log of all resource transfers "APNIC will maintain a public log of all transfers."

Clarification:

Should APNIC maintain a public log of all resource type (IPv4, IPv6, ASN) transfers, including historical IP addresses and scenarios due to merger, acquisition, or takeover?

Recommendation:

In the spirit of this proposal, for reasons of consistency and no changes to the current transfer policies, we recommend the proposal authors and the community to trust the Secretariat to do the right thing in combining all relevant transfers policies under a new Part (Part 5 of the Policy document), without relying on the proposed text in the proposal.

Implementation:

This proposal would not require any changes to the systems.
If this proposal reaches consensus, implementation can be completed within 3 months.

Regards,
Sunny and Odagi
Policy Support

Dear SIG members,

The proposal "prop-142: Unify Transfer Policies Text" has been sent to
the Policy SIG for review.

It will be presented at the Open Policy Meeting (OPM) at APNIC 53 on
Wednesday, 02 March 2022.

https://conference.apnic.net/53/program/schedule-conference/#/day/10

We invite you to review and comment on the proposal on the mailing list
before the OPM.

The comment period on the mailing list before the OPM is an important
part of the Policy Development Process (PDP). We encourage you to
express your views on the proposal:

- Do you support or oppose this proposal?
- Does this proposal solve a problem you are experiencing? If so,
tell the community about your situation.
- Do you see any disadvantages in this proposal?
- Is there anything in the proposal that is not clear?
- What changes could be made to this proposal to make it more effective?

Information about this proposal is appended below as well as available at:

http://www.apnic.net/policy/proposals/prop-142

Regards,
Bertrand, Shaila, and Ching-Heng
APNIC Policy SIG Chairs



---------------------------------------------------------------

prop-142-v001: Unify Transfer Policies Text

----------------------------------------------------------------

Proposer: Jordi Palet Martínez (jordi.palet@theipv6company.com)
Amrita Choudhury (amritachoudhury@ccaoi.in)


1. Problem statement
--------------------
Presently the transfer policies have been listed separately for different type of number resources.
Sections 8.0 to 8.4 of the policy manual contains the text for IPv4 transfers (including Historical
Resources), section 11.0 is equivalent for IPv6 transfers (only M&A). and section 13.0 to 13.3, provide
equivalent text for ASN transfers.

As a result, there is duplication of text in different parts of the manual, which clearly make the
reading and interpretation more complex.



2. Objective of policy change
-----------------------------
The objective of this proposed change is to ensure there is a single coordinated section for all kind
of transfers, reduce the duplication of pieces of text and make it easier for people to access the
relevant information.

While this change can be done by the secretariat as an editorial change, but seems that they prefer
to ensure that the community confirms their acceptance.

The proposal IS NOT intended to change the existing transfers policies, so only minor re-wording/re-phrasing
is being done in order to shorten the text, avoid duplicities and making it easier to read and interpret.



3. Situation in other regions
-----------------------------
Different RIRs have unified the text, but the policy manual in others is separate documents for each policy
so that’s not feasible.


4. Proposed policy solution
---------------------------
Replace actual Policy sections with:

Part 5: Resource Transfers

APNIC recognizes that there are situations where resources (IPv4, IPv6, ASN) may need to be transferred.

APNIC does not recognize any transfer outside this policy and require organizations holding such transfers
to return them to the appropriate IR.

The Resource Transfer policies ensure that all transfers are accurately reflected in the APNIC Whois Database.
This ensures the integrity of the network and an accurate description of the current state of address distribution.

APNIC will maintain a public log of all transfers.

In the case of IPv4, addresses delegated from the 103/8 free pool cannot be transferred for a minimum of five
years after the original delegation. During that time, if the reason for the original request is no longer
valid, the resources must be returned to APNIC as required in Section 4.0. Resource License.


11.0. Intra/Inter-RIR Transfers

APNIC will process and record IPv4 and ASN Intra-RIR (between current APNIC account holders) and Inter-RIR
Transfers (between current APNIC account holders and organizations in other RIR regions).

In the case of Inter-RIR transfers, APNIC will process and record transfers only when the counterpart RIR
has a reciprocal policy.

11.1. Conditions on the Resources to be transferred

The resource must be:
• Under the management of the RIR at which the transfer source holds an account and the authentic
holder of the space should match with the source without any disputes.
• Delegated to a current RIR account holder.
• If the recipient is an APNIC account holder, will be subject to all current APNIC policies from the time of transfer.
• In the case of IPv4 resources, the minimum transfer size is a /24.


11.1.1. Historical IPv4 Resources

Transfers of Historical IPv4 resources as defined in Section 2.5.2 can optionally follow this policy.
In that case, the transfer will be recognized and registered by APNIC.

APNIC does not require any technical review or approval of the resource’s current use to approve the
transfer. In addition, APNIC does not review any agreements between the parties to a transfer and
does not exert any control over the type of agreement between the parties.

If the historical Internet resources are not held under a current APNIC account, the recipient entity
must verify they are the legitimate holder of the Internet resources.

For more information on transferring historical Internet resources, please see the transfer page of the APNIC website.

https://www.apnic.net/transfer


11.2. Conditions on the Source of the transfer

The conditions on the source of the transfer will be defined by the RIR where the source organization
holds an account. This means:

• For transfers from an APNIC source, the source entity must be the currently registered holder
of the IPv4 address resources, and not be involved in any dispute as to the status of those resources.
• Where the source is in another region, the conditions on the source as defined in the counterpart RIR’s
transfer policy at the time of the transfer will apply.

11.3. Conditions on the Recipient of the transfer

The conditions on the recipient of the transfer will be defined by the RIR where the recipient organization
holds an account. This means:

• For transfers to an APNIC recipient, the entity will be subject to current APNIC policies.
o For IPv4 transfers:
- Recipients that do not already hold IPv4 resources must demonstrate a detailed plan for the use of
the transferred resource within 24 months.
- Recipients that already hold IPv4 resources must:
- Demonstrate a detailed plan for the use of the transferred resource within 24 months,
- Show past usage rate, and
- Provide evidence of compliance with APNIC policies with respect to past delegations.
• For ASN transfers the recipient entity must meet the criteria for the assignment of an ASN
• Where the recipient is in another region, the conditions on the recipient as defined in the counterpart
RIR’s transfer policy at the time of the transfer will apply.

12. Mergers & acquisitions

APNIC will process and record the transfer of IPv4, IPv6 and ASN resources as the result of merger or acquisition.

12.1. Updating registration details

If an organization changes ownership (due to a merger, sale, or takeover), then the new entity must register any
changes to its network usage and contact personnel with APNIC. If the effect of the ownership change is that the
name changes, then the organization must provide relevant legal documentation to APNIC supporting the changes.

12.2. Effect on membership agreement

If an organization changes ownership then the new entity should update APNIC of the change. APNIC membership is
not transferable from one entity to another; however, if the effect of the ownership change is that the organization
becomes a subsidiary of another entity, and the infrastructures of the respective entities remain fully independent,
then the membership agreement may continue.

12.3. Consequences for delegations
Following a change in ownership, APNIC will review the status of any delegations that are held by the new entity or
entities, with regard to the practical effect on their infrastructures.

If the practical effect of ownership change is that the infrastructures are merged, then APNIC will not continue to
make separate allocations to both. This situation will invalidate the membership agreement of the organization that
is effectively subsumed.

When assessing the status of delegations, APNIC requires full disclosure of all address space held by all of the
entities in question. If full disclosure is not made, then APNIC will consider any delegations to be invalid and
will require that they be returned.


5. Advantages / Disadvantages
-----------------------------
Advantages:
It creates a unified transfer policy section that is concise (by shortening the text by almost half) and easy to access.

Disadvantages:
None.


6. Impact on resource holders
-----------------------------
None.


7. References
-------------
Nil.

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