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:
 
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1. Non-compliance with RIPE Policies: SSA termination and deregistration
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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which is no longer applicable.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.
 
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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.
 
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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.
 
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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