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Everything you need to know about ICANN's

new transfer policy

Latest update: December 1, 2016

On December 1, 2016, ICANN started enforcing a new transfer policy that modifies the
process of changing domain ownership from one registrant to another. The implementation
of the policy is imposed on all registrars. We have created this resource page to ensure that
all OpenSRS resellers are ready for this policy. We encourage you to review this policy update
to familiarize yourself with all of the changes that are being made to the transfer policy.

What is this policy?

When is it going into effect?
How will it impact your business?
What is OpenSRS doing?
How does the new process work?
Preparing for the new policy
Questions our resellers have been asking
End-user frequently asked questions

What is this policy?

The policy we are discussing here is the Transfer Policy, formerly known as Inter-Registrar
Transfer Policy or IRTP. Up until now, this policy only covered domain transfers between
registrars (its the policy that mandates the Forms of Authorization to be completed by a
registrant prior to a transfer). The new policy also covers the process of changing ownership
of the domain from one entity to another (registrant to registrant). Every time a change of
registrant takes place, the policy is called upon and a series of confirmation and approval
emails are triggered. Whats important to note is that simple updates to a registrants first

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name, last name, organization and email address on a particular domain also triggers the
same slew of notification and confirmation emails.

When is it going into effect?

The new transfer policy is effective on December 1, 2016.

New transfer policy timeline

We have been working actively on the implementation of this policy. The timeline below will
give you an indication of how the work is progressing.

How will it impact your business?

Once the policy is in effect, the impact on resellers and their end users will be visible. It can be
summarized as follows:

It will no longer be possible to change the registrant of a domain name with a simple
domain modification request.
Any changes to first name, last name, organization or email address fields for the
owner of any gTLD domain name will now start a trade process.
The process involves obtaining explicit confirmation from current and new registrants
before a change can be completed.
After a change of registrant has been completed, previous and new registrant will
receive a confirmation notice informing them that the change has completed
After a change of registrant has been completed, the domain is by default locked for
transfers to a new registrar for the following 60 days

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What is OpenSRS doing?

At OpenSRS, we believe that the ICANN community who came up with this new policy did a
disservice to registrants. The policy requirements do not add any positive element to the
experience of managing a domain name, and there has been no consideration how this
policy would align with the number of other ICANN mandated policies which are already in
place. Nonetheless, OpenSRS is, like all other ICANN accredited registrars, bound by the
terms of the Transfer Policy, and needs to follow due process.

Our approach in implementing this policy is:

To design the required processes in a way that meets policy terms and withstands an
ICANN audit.
To minimize the actual negative impacts for resellers and end-users.
To leverage policy options such as the Designated Agent or transfer-lock opt-outs to
streamline the process and reduce registrant impact as much as possible.

Our approach is to ensure resellers do not necessarily need to make adjustments to their
systems to support the new policy. OpenSRS will be able to handle all necessary basic
requirements, and provide some optional tools and features that allow resellers to optimize
handling of this policy.

How does the new process work?

The process starts with the reseller submitting a request to modify the owner of a given
domain name.

OpenSRS will then check if the New Registrant has previously accepted Tucows to act as a
Designated Agent (DA). If so, OpenSRS would auto-approve the change for the New
Registrant. Otherwise OpenSRS will send an email to the New Registrant, asking them

to approve or decline the Change of Registrant,

to confirm that their information is correct (as per Registrant Verification), and
accept Tucows to act as a Designated Agent for all future changes of registrant
(optional)

Once the change has been approved by the New Registrant, OpenSRS will check if the Prior
Registrant has accepted Tucows to act as a DA. If that is the case, OpenSRS would auto-
approve the change for the Prior Registrant. Otherwise, OpenSRS will send an email to the
Prior Registrant, asking them

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to approve or decline the Change of Registrant, and

opt out of the 60-day registrar transfer lock after a Change of Registrant (optional).

After both approvals have been recorded, OpenSRS will complete the Change of Registrant
and send a final confirmation to both Prior and New Registrant which notifies them about the
completed process. In this scenario, the New Registrant will not receive a subsequent email
to complete the Registrant Verification process, as this has already been completed with the
initial confirmation.Even if the email of Prior and New Registrant is the same, the policy
requires OpenSRS to send two separate emails. There is no further response required from
registrants at this point of the process.

In case the New or Prior Registrant decline a change, or the request times out after 7 days,
the entire process is aborted, and the present owner details will stay in place.

To help you better understand how this works, we have simplified the new process into five
likely scenarios that may apply to all resellers. Please note: our systems will accommodate all
scenarios.

Scenario A
New Registrant uses Tucows as Designated Agent
Old Registrant uses Tucows as Designated Agent

Scenario B
New Registrant doesnt use Tucows as Designated Agent
Old Registrant uses Tucows as Designated Agent

Scenario C
New Registrant uses Tucows as Designated Agent
Old Registrant doesnt use Tucows as Designated Agent

Scenario D
New Registrant doesnt use Tucows as Designated Agent
Old Registrant doesnt use Tucows as Designated Agent

Scenario E
End User buys a domain from someone using another registrar and transfers
to Tucows

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Master Chart

Preparing for the new policy

1) Make sure you present our updated Registration Agreement to all your new and
existing customers whenever they submit a domain-related request.

2) If you have integrated with our API, familiarize yourself with the additional API
commands that we are providing.

3) To ensure that emails sent to current and new registrants reflect your language and
brand, we have added and translated three new templates to our messaging
platform:
Change of Registrant Confirmation for New Registrant
Change of Registrant Confirmation for Current Registrant
Notification for Completed Change of Registrant

4) Change the link colours and add a custom URL for your confirmation pages under
brand settings within the Reseller Control Panel. If you havent uploaded your logo
yet, now is a good time to do so. IMPORTANT: confirmation pages will be shown in the
same language as the Change of Registrant emails.

5) Enable Designated Agent (turned off by default) for all existing domains.

What is a Designated Agent in the context of this policy?

The Transfer Policy allows Registrants to delegate giving their consent to a Change of
Registrant to a third-party on their behalf. The policy defines such third-party as a Designated
Agent (DA):

1.2 Designated Agent means an individual or entity that the Prior Registrant or New
Registrant explicitly authorizes to approve a Change of Registrant on its behalf.

In practical terms, this means that a Registrant can give authority to Tucows (the legal entity
that operates the OpenSRS registrar) to confirm a Change of Registrant. When Tucows is
enabled to act as a Designated Agent, the Registrant will not need to receive or confirm an

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email in order for a change to proceed. Instead, Tucows will always auto-approve any Change
of Registrant.

In order to support this option, Tucows has made a change to its Registration Agreement,
which is the legal document that each and every Registrant has to accept in order to manage
a domain name through OpenSRS. In this agreement, we have added the following language:

21. TRANSFER OF OWNERSHIP. [] Registrant explicitly authorizes Tucows to act as their

Designated Agent, as stipulated by the ICANN Transfer Policy, to approve a Change of
Registrant on their behalf.

View Registration Agreement

As a reseller, you are required to incorporate all provisions of this agreement in the
agreement with your customer, so we advise to update your agreement to the latest version.
We may be required to provide evidence to ICANN that your customer has actually accepted
those terms, including your customers timestamp and IP at the time acceptance.

How can I enable the Designated Agent option for my reseller

account?
We will provide you with an option in the Reseller Control Panel to confirm that you meet all
the legal requirements. Specifically, we will ask you to confirm the following:

You have incorporated the Tucows Registration Agreement in its latest version into
the contract with your customer/domain registrant. The latest version includes a
provision for the registrant to accept Tucows as Designated Agent.
You are requesting a domain registration or transfer at OpenSRS only after the
registrant has entered into such agreement.
You can present proof, upon future request, that a registrant of a specific domain has
accepted a contract that binds them to our Registration Agreement. Proof could be a
timestamp log (e.g. 3:00UTC, date: 21/2/13, domain: example.com, registrant: John
Doe, registrant IP: 122.111.222), a copy of a written and signed contract, or a
screenshot of an Executed Agreement for the domain including domain name,
registrant, and date/time of execution). We will ask you for this information if ICANN
requests us to present this during an audit.

Once you have confirmed this, we will mark all registrants of existing domains in your reseller
account as having accepted Tucows as their Designated Agent for the Transfer Policy.

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What is the process if both the New and the Prior Registrant have
accepted Tucows as a Designated Agent?
In this case, the entire process completes immediately without Registrant approvals required.
Both Prior and New Registrant will receive a notification about the completed change. The
New Registrant will subsequently receive an email request to complete the Registrant
Verification process.

What happens if the current registrant email is invalid or not

accessible?
If a confirmation email sent to the New or Prior Registrant bounces, or it is no longer
accessible, the reseller will have the opportunity to resend the confirmation request

to the same email address (if the bounce was just temporary), or
via SMS to the phone number supplied for the Registrant.

If the phone number is incorrect, the reseller has the option to update the current registrant
details with a new, valid mobile phone number. Updating just a registrants phone number is
not considered a change of registrant by the Transfer Policy, so OpenSRS will process this
update without confirmation. Once the phone number is correct, the reseller can then
resend the confirmation email to the new, updated phone number.

SMS approval link scenario

How will I know if my request has timed out or has been denied?
How will I know when the change is approved by the prior and
new registrant contact?
A setting will be available in the Event Notifications Tab (In the Reseller Control Panel) to
enable either a poll and/or email message notification. Tucows will also introduce a new,
internal status that well make available to Resellers

Questions our resellers have been asking

Q: Where do I find details about the new APIs that OpenSRS is providing for this policy?
A: We have added documentation for the additional API calls to our online API

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documentation available at domains.opensrs.guide. Please see the ICANN Trade section

for all new API commands.

Q: Should I make the New Registrant accept the Designated Agent option on my own
portal? Does it make the process a lot easier?
A: The short answer is, we give you option to do so, but a New Registrant will still receive a
confirmation email.

The Transfer Policy requires every New Registrant accept our Registration Agreement during
the process, which has the provision for Tucows to act as a Designated Agent. Resellers have
the option to collect the New Registrants acceptance of our agreement on their end for
example once your customer is logged in at your portal and clicks a checkbox before they
submit the Change of Registrant request. OpenSRS provides an API that enables resellers to
set the New Registrant having accepted Tucows as a Designated Agent before you initiate
the actual Change of Registrant process. View documentation. In this case the New
Registrant would not receive a Change of Registrant confirmation email.

However, even in this scenario the New Registrant will still receive a Registrant Verification
email after the Change of Registrant has been completed. Otherwise, if the New Registrant
has not accepted our Registration Agreement prior to submitting the change, we will
complete the Change of Registrant confirmation and Registrant Verification process with a
single email being sent.

So either way, the New Registrant will be required to confirm one email, and will receive a
notification for the completed Change of Registrant.

Q: Is it correct that once a Registrant accepts Tucows as Designated Agent (DA), the
Registrant itself has no way to revert this decision, and only the reseller can disable
the DA setting?
A: This is correct. Only the reseller can revert the DA setting on behalf of a Registrant via a
specific API. View documentation

Q: Will a Current Registrant be able to accept Tucows as a Designated Agent when

confirming a Change of Registrant?
A: A Current Registrant would receive a confirmation email only in a scenario where they
havent accepted Tucows as their Designated Agent yet, or their reseller has disabled that
setting for them. For this scenario, we have decided against giving the Current Registrant the
option to accept Tucows as the DA, as generally they will soon no longer be the registrant at

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all. While theoretically they still could be a registrant for other existing or future names, it
would be difficult to understand this scenario to the user exposed to the confirmation page.

Q: Consider the following scenario:

Alice as a New Registrant approves a Change of Registrant and accepts Tucows as a DA. The
change completes, and the domain is transfer-locked for 60 days.

5 days later, Alice changes ownership of the domain again to Bob as the New Registrant. Bob
as the New Registrant accepts the change.

As Alice has previously accepted Tucows as the DA, OpenSRS will auto-approve the change
for Alice as the Current Registrant, without giving Alice the chance to opt-out of the transfer
lock.

Is there any way for Alice to still opt-out of the transfer lock? And if there is, will she be
able to override the transfer-lock setting from the previous transfer?

A: It is correct that in this scenario Alice would not receive a confirmation email which would
allow her to opt-out of the transfer lock. However, as a reseller you can give Alice the option
to opt-out of the transfer lock in your portal at the time when she changes the registrant to
Bob. OpenSRS provides an API to modify the transfer lock setting prior to submitting a
Change of Registrant. View documentation

If Alice opts out of the transfer lock, her choice will override the transfer lock that was applied
from the previous Change of Registrant, and the domain will not be locked after the change
has completed.

Q: As all our existing registrants will have accepted the registration agreement,
Tucows will be the Designated Agent and auto-approve Change of Registrant requests
for them as the Current Registrant. Due to the auto-approve, they will not have the
option to opt out of the transfer-lock. Does this mean that in this scenario the transfer
lock will apply to all domains coming out of a Change of Registrant process?
A: Yes, all Current Registrants who have accepted Tucows as DA will not get a confirmation
email, so by default the transfer lock will apply to them. Resellers who want to give their
customers the option to transfer the domain away to another registrar anytime after a
change can do so by implementing the modify_trade_lock_setting API. View
documentation

Q: Why do I need to submit a domain name when setting the Designated Agent option
for an existing registrant via the modify_trade_lock_setting API? Doesnt the

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Registrant accept the Registration Agreement for all domains they own?
A: We ask for the domain name as a simple way to specify which registrant has accepted the
Registration Agreement. When you use that API, OpenSRS will look up the owner contact of
the given domain and set the DA accepted option for the specific firstname, lastname,
organization, email combination found in that owner contact. The DA setting will then apply
for all existing or future domains that share this unique combination as a Current or New
Registrant.

Q: Can I automatically opt-out of the 60-day transfer lock for all of the domains in my
reseller account?
A: No, the policy does not allow us to provide such setting on a reseller level. The language of
the Transfer Policy specifies that only the Registrant themselves can opt-out of the transfer-
lock.

Q: What happens if all I do as a reseller is to update the Registration Agreement to

include the Designated Agent option, without implementing any technical changes?

A:

Once you confirm that you have updated your registration agreement, OpenSRS will
enable the Designated Agent (DA) setting for registrants of all your existing domains.
OpenSRS will automatically enable the DA setting for registrants of all new domains or
domains that are being transferred in from another registrar.
When a Change of Registrant occurs, OpenSRS will send out a confirmation email to all
NEW registrants, asking them to confirm the change and complete registrant
verification in a single step.
Once the New Registrant has confirmed the change, OpenSRS will auto-approve for
the Current Registrant and send a notification email to both old and new registrant
informing about the completed change.
The domain will be transfer-locked for 60 days

Q: Does this implementation of the new transfer policy also apply to country-code top-
level domains (ccTLDs)?
A: No, it only applies to generic top-level domains (gTLDs) which are all governed by ICANN
policies. ccTLDs usually have their own policies, and are not affected by these changes.

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Q: How does this new policy affect using whois privacy on domains?
A: We have changed the terms of our Whois Privacy Service to require the registrant to
accept Tucows as a Designated Agent. This will allow to enable and disable the whois privacy
setting on a domain without going through an email confirmation process. When disabling
Whois Privacy, we as the Current Registrant will always opt-out of the 60-day transfer lock, so
it will be possible to disable whois privacy just prior to a transfer.

In a scenario where a domain has whois privacy enabled, and the actual registrant is
changing, it will follow the usual confirmation process as if whois privacy was not enabled.

Q: Am I able to customize the emails that go out to new and current registrants?
A: To ensure that emails sent to current and new registrants reflect your brand, we have
added 3 new customizable email templates to our messaging platform:

Change of Registrant Confirmation from New Registrant

Change of Registrant Confirmation from Current Registrant
Notification for Completed Change of Registrant

IMPORTANT:
Only the English templates can be modified at this point. Translated templates will be
available on November 29th.

Given that the new transfer policy relies heavily on the messaging platform to function, our
old messaging platform will be disabled and your account will be automatically migrated to
the messaging platform on November 30th. To prevent any loss of customizations, please
recreate your messages in the new system. If you are using the messaging platform, you
are good to go.

Q: Am I able to customize the confirmation page that new and current registrants will
see after they click the emails?
A: New branding settings that allow you to customize these confirmation pages will be
available in the Reseller Control Panel on November 24th. Confirmation pages will be shown
in the same language as the Change of Registrant emails. Translation for confirmation pages
will be added on November 29th (alongside translated email templates).

End-user frequently asked questions

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As we have stated before, this is a complex policy that has the potential to disrupt your
current processes. To help your end-customers understand these changes, we have
developed questions and answers. This section will constantly be updated to ensure your
customers have the most current information.

Q: What would trigger this change of registrant process?

A: Making any change to the first name, last name, organization field, or email within the
registrant contact object, will start the process. An approval email will go out to both the old
and new registrants.

Q: What happens if its not an actual transfer but minor updates to first name, last
name, email or organization field?
A: At this time, any change to any of those fields will begin the change of registrant process.

Q: Who has to approve the change of registrant request?

A: Both the new and the prior registrant need to approve the change of registrant request.

Q: What if I am both the old and the new registrant?

A: You will be required to approve the change of registrant request twice.

Q: What happens if the new registrant approves the request but the old registrant
denies the request?
A: This will cancel the whole request and the whois will revert back to the previous registrants
info.

Q: What happens if the new registrant denies the request ?

A: Then the change of registrant request is canceled and the previous whois info remains the
same.

Q: What happens if I am the new registrant and I do not receive the email request to
approve the change of registrant?
A: Your domain provider will be able to resend the email, otherwise the process will timeout.
You will need to start the process again using a different email address.

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Q: How long does the new registrant have to approve the request before it
expires/times out?
A: 7 days from the change request.

Q: What happens if I submit another change of registrant request when one is

currently pending?
A: The first request will be cancelled.

Q: What if I dont have access to my old email address?

A: Your domain provider can explicitly send a link via SMS to the phone number that they
have on file. This will allow you to approve the change of registrant request.

Q: What happens if the number on file is not a mobile phone number?

A: Depending on the service we use, we may be able to use features available that can
contact registrants at a land line. Otherwise, it is recommended to update the phone number
field with a mobile number.

Q: What happens if I buy an aftermarket name, and then the prior registrant does not
approve the change of registrant
A: Prior to a registrant listing a domain name for sale (at Afternic or Sedo), registrants will be
required to appoint Tucows as the designated agent in order to list their names

Q: After a Change of Registrant, are there any restrictions on transferring that name?
A: If you want to transfer and change the registrant at the same time, you should transfer the
domain first, and then the change the registrant. Failure to do so will result in your domain
being locked for 60 days.

Q: Is there anyway to opt out of the 60 day lock after a change of registrant is applied?
A: Yes, OpenSRS will offer the prior registrant a chance to opt out of the 60 days transfer lock
at the time of the initial Change of Registrant request. This option can be enabled via the End
User Control Panel, or through your Domain Provider.

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