prop-168: Increase to maximum IPv4 delegations

Current address policy only allows for the maximum delegation of up to and including a /23 to new and existing account holders.

This policy change will allow a sub-set of account holders with less than an aggregated /22 to receive an additional delegation of up to a maximum of a /22 IPv4 delegation.

Christopher Hawker

This Impact assessment is for prop-167-v001

1. APNIC’s Understanding of the Proposed Policy

This policy proposal (Proposal) aims to increase the maximum IPv4 Delegation size from /23 to /22.
This option would be available to all account holders that meet the appropriate criteria.

All requests for additional address space would still be subject to needs assessment.

Account holders who have transferred any IPv4 number resources out of their account would not be eligible for additional address delegations.

This Proposal also makes changes to the ability for account holders to transfer out resources. For resources delegated by APNIC to an account holder, that account holder would not be able to transfer those resources for 5 years from the date of their most recent delegation from APNIC. For example, if you received your initial delegation from APNIC in 2018, and an additional delegation from APNIC in 2026, then the initial delegation received in 2018 would not be eligible for transfer until 2031. This transfer restriction would not apply to resources that have been transferred into the account holder’s account.

There would also be an additional reserved /16 pool of IPv4 for account holders who take up and deploy IPv6, to utilise a /24 IPv4 for transitional purposes. This IPv4 assignment cannot be transferred and must be returned at completion of transition to IPv6. Any assignments returned would remain within this same reserved pool.

The Secretariat notes that the objective mentions that this Proposal is only applicable to account holders that have joined since the introduction of prop-127, however the Proposal’s policy solution makes no mention of this. The Proposal would need to be amended to ensure consistency between the proposed policy solution and objective. For the purposes of this Impact Analysis, the Secretariat has assumed that the Proposal’s policy solution is accurate.

The Secretariat has assumed for the purpose of this analysis that historical resource holdings would be included in calculations for resource holding under the eligibility criteria. However, it is unclear if it is intended that historical resource holdings would be affected by the transfer restrictions as these encompass resources “delegated prior to APNIC’s establishment or before APNIC introduced a membership structure” (amongst other criteria) and as such constitute a mix of resources delegated by APNIC in its earlier form or by another registry. The current Proposal language provides that the transfer restrictions would apply to “any resources delegated from the available pool” and as such could be interpreted to apply to a subset of historical resource holders but not others. The Secretariat assumes that historical resource holdings will not be subject to the transfer restrictions contemplated by this Proposal as they were allocated before the concept of the “available pool.”

2. Impact of Proposed Policy on Registry and Addressing System

If the Proposal was to reach consensus, the IPv4 available pool would likely be exhausted within months (subject to needs assessment and validation of applications). APNIC would be left with some reserved space under prop-62/144/156.

As at 21/01/2026, there are 12,077 X /24 in the free pool with approximately 15,775 accounts (including NIR) that could potentially be eligible. Total address requirements would be ~42,218 X /24 if all potentially eligible accounts were to seek the additional space.

There is already provision in policy for re-instatement of a waitlist (section 6.1) however this may require amendments as outlined below.

If this Proposal becomes Policy, the Secretariat suggests that the waitlist text in section 6.1 be changed from “A waiting list will be created once APNIC runs out of all IPv4 addresses.” to “A waiting list will be created once APNIC has exhausted the 103/8 IPv4 address pool.” This would allow for the waitlist to be created for ordinary IPv4 delegations while the proposed /16 reserved pool for IPv6 transition still exists (if that is the intention of the proposal).

The proposed section 5.1.5 will require a reservation of a /16 (256 X /24) for IPv6 Transition. The Secretariat notes that a more prudent threshold may be /12 (4096 X /24) which would provide a runway, based on new accounts (including NIR), of approximately 40 months. This is based on linear projections from the last 5 years extended into 2030 and does not factor in account closures/reclaiming addresses. If this pool were to be exhausted, the Secretariat anticipates a need to create a separate waiting list from which any returned or reclaimed space originally delegated from this /16 would be reassigned.

3. Impact of Proposed Policy on APNIC Operation/Services

If this Proposal was to reach consensus, the Secretariat anticipates a large volume of applications. This will add significant delay to processing of applications unless additional staff are retained.

Changes would be required to back-end and front-end systems to re-instate the waiting list.

4. Legal Impact of Policy

Changes are recommended to the Proposal to ensure consistency of language and use of terminology such as “available pool” (the policy document does not use the term “available pool” at present, instead referring to “103/8 pool”) and “members” (the policy document refers to “account holders” to ensure both Members and Non-members are represented). We note the proposed removal of paragraph 3 from section 6.1 will remove the references to “recovered non-103/8 resources [being] considered the same as 103/8 addresses” which would suggest that recovered non-103/8 resources are to be treated differently if this Proposal becomes policy.

Clarity is also requested from the author on whether the Proposal is intended to impact any other policies such as IXP (6.2.4), temporary assignment (15.1), or experimental (5.7) policies.

For Example: Company A can join and apply for /24 under last /8 policy and grow that up to /22. After that, they can apply for /26 under prop-154 IXP policy and grow that up to /22 as IXP assignments are not delegated under the last /8 policy. In this way, company A ends up with total of /21 IPv4.
Company B can join and apply for /26 under prop-154 IXP policy and grow that up to /22. They can also apply for /24 under last /8 policy but they will only be able to grow that to /23 because they already hold /22 under IXP policy.

The addition of Section 5.1.5 may create a procedural and timing conflict as the trigger event for enablement of the /16 pool in this proposal is the exhaustion of the available address pool which is also the trigger event for the /16 reservation under section 5.1.1 (from Prop-62). It is unclear if the intention is for the /16 pool in this proposal to only come into effect after the /16 pool in section 5.1.1, or at the same time.

The Secretariat notes that the changes in section 11.1.1 would not apply to resources that have been transferred in by account holders from other RIRs

5. Implementation

If this policy was to reach consensus, implementation would be approximately 4 months subject to call for editorial comments.