Dear colleagues, The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has been reviewed and updated. You can find the updated document at: https://www.ripe.net/publications/docs/ripe-833/. The following amendments were made: ----------------------------------- 1. Non-compliance with RIPE Policies: SSA termination and deregistration ----------------------------------- Section A.1.2. Termination by the RIPE NCC (1.2.1.1.b.) was amended through the addition of the word “repeatedly”. Previously the Closure Procedure suggested that allocations and assignments in contravention of the RIPE policies could lead to the termination of the SSA, even if the contravention took place only once. The amendments suggest that the SSA may be terminated if allocations and assignments are repeatedly not made and used in accordance with RIPE policies. This change creates an escalation process. If a violation of the RIPE community’s policies occurs only once, we will proceed with the deregistration of relevant resources. In case such violations take place repeatedly, we will proceed with the termination of the SSA. Section B. Deregistration of Internet Number Resources (1.b.) was amended by replacing “Invalidity of assignment criteria [...] relevant Internet number resources” with “Allocations/assignments in contravention of RIPE Policies [...] deregister the relevant records”. This provision only addressed a certain type of RIPE policy violation, which is no longer applicable. With these amendments, the old criterion has been removed and it allows the RIPE NCC to deregister the relevant records if allocations/assignments are not made and used in accordance with any RIPE policies. ----------------------------------- 2. SSA/Legacy Agreement termination for non-payment ----------------------------------- Members must pay their fees within 30 days from the date of the invoice. According to the previous version of the Closure Procedure, the RIPE NCC terminated the progress of any open requests for services and suspended the membership after 90 days from the date of the invoice. This time period has changed to 60 days and subsequently, Sections A. Closure of Member – Termination of the RIPE NCC Standard Service Agreement, (1.2.2.e.) and C.1. Termination of the Legacy Services (1.2.2.2.e.) have been amended accordingly to reflect this change. ----------------------------------- 3. Legacy Internet Resources ----------------------------------- The Closure Procedure previously stated that if the RIPE NCC became aware of reasons for terminating or upon the termination of the Legacy Services/Agreement, the RIPE NCC would take certain measures, such as: - Add the remark “No-contract”/”Under Review” in the RIPE Database resource object - Add a warning statement to the relevant records in the RIPE Database mentioning that the Legacy Internet Resources are not covered by a contractual relationship/are not in compliance with data accuracy requirements - Revoke any certificates generated by the RIPE NCC Resource Certification (RPKI) Service relating to Legacy Internet Resources - Withdraw the reverse delegation These measures should not be applied for the following reasons: - Technical amendments regarding attributes in the RIPE Database that took place some years ago allow resource holders to add, change, or remove some attributes, including the remarks line. The requirement for the RIPE NCC to add remarks/statements in the RIPE Database is no longer relevant, as the remarks can be removed at any time by the Legacy Holder. - RIPE NCC Certification (RPKI) Service is only revoked after the termination of the Legacy Services/Agreement and not when the RIPE NCC first becomes aware of any reasons for terminating the Legacy Service/Agreement. - Reverse DNS is an essential service that cannot be denied and RIPE NCC provides it regardless of the contractual status. Therefore, Sections C.1. Termination of the Legacy Services (1.1.2.1. and 1.2.2.1.) and C.2 Consequences were amended accordingly to reflect the above. Also, the Closure Procedure previously stated that upon deregistration of Legacy Internet resources, the RIPE NCC would: - Withdraw the reverse delegation; and - Delete all relevant objects in the RIPE Database, including allocation/assignment and route objects. Upon deregistration, we also revoke any certificates generated by the RIPE NCC Certification (RPKI) Service, therefore this step was added to Section C.4. Deregistration of Legacy Internet Resources which was amended accordingly. ----------------------------------- 4. Other changes ----------------------------------- 4.1. Section A.1.2. Termination by the RIPE NCC (1.2.1.2.) Previously the Closure Procedure stated that the termination notice would officially inform about the termination of the SSA, state the reasons for the termination, and detail the planned arrangements regarding the Internet number resources that were distributed to the Member. The wording "distributed to the Member" implied that resources were distributed to the Member by the RIPE NCC and may exclude resources received via transfers or Legacy Internet resources. For clarity, we replaced the wording “distributed to” with “registered to”. 4.2. Section A.2.1.2. Registration of Distributed Internet Number Resources We removed the word “distributed” from the title, since it implied that Internet resources were distributed to the Member by the RIPE NCC and may exclude resources received in any other way. We also added a note to clarify that this section does not apply to Legacy Internet Resources. 4.3. Sections: A.2. Consequences (2.1.1., 2.1.2.), B2. Procedures for Deregistration of Different Types of Internet Number Resources (2.1., 2.2.) In several sections, the RPKI service is referred to as RIPE NCC Resource Certification (RPKI) Service. RIPE NCC Certification (RPKI) Service is how it is referred to in RIPE NCC Certification Service Terms and Conditions. For consistency purposes, this wording is updated throughout the Closure Procedure. 4.4. Section A.2. Consequences 2.1. End of Provision of RIPE NCC Services (2.1.1.) The previous wording stated that by the end of provision of RIPE NCC Services, the RIPE NCC would stop providing services, including participation in RIPE NCC training courses. Since last year, training courses (webinars) are available to non-members, therefore we updated the wording “RIPE NCC training courses” to “training and certification services offered to Members”, which is more accurate. Kind regards, Theodoros Fyllaridis Legal Counsel RIPE NCC