Since March 2026, a multi-stakeholder Working Group has been developing policy on the concept of an Associated Domain Check (ADC) as part of the ICANN’s Policy Development Process (PDP) ( “PDP 1”). On 18 August 2026 the Working Group issued their Initial Report for comment. The NetBeacon Institute congratulates the Working Group and ICANN Staff on producing the preliminary recommendations and implementation guidance.  Creating policy for a global interconnected infrastructure system is not a simple endeavour. This PDP sets a new standard for how to set scope, define issues and move at pace, all while ensuring sufficient discussion and flagging future work. Kudos to everyone who contributed to this work.

We believe the proposed recommendations and implementation guidance will incentivize the domain industry to implement checks and balances to mitigate malicious campaigns of DNS Abuse. Unearthing related domains used in large scale malicious activity is a meaningful and important step forward. As our data shows, malicious DNS Abuse campaigns can be concentrated, and impactful, such as impersonating governments to target citizens accessing social services. We hope contracted parties pair ADCs with preventative measures to make a material difference on both the prevalence and persistence of malicious DNS Abuse campaigns.

This work also raised the issue of registrant recourse. We support future work on this topic as a separate PDP to ensure it covers all registrants, not just those whose domains are flagged as part of an ADC, as per our proposal. 

Building off the success of PDP 1, we appreciate the current work in the gNSO Council on drafting the charter for PDP 2, and we look forward to the next Working Group beginning its deliberations. While we believe that PDP1 will have a huge impact on swiftly mitigating abusive campaigns, we believe that PDP2 will have an even bigger effect at helping to prevent them. 

Thank you to ICANN Staff and Community for the opportunity to provide these comments, and we wish the Working Group continued success as it resumes its work at ICANN87.

*The NetBeacon Institute is a part of Public Interest Registry, which participated in the PDP for the gTLD Registries.