------------------------------------------------------- prop-130-v003: Modification of transfer policies ------------------------------------------------------- Proposer: Jordi Palet Martínez jordi.palet@theipv6company.com 1. Problem statement -------------------- Existing transfer policies for IPv4, IPv6 and ASN resources have some differences among what is allowed and what not, if in the case of intra-RIR and inter-RIR, and it is not clear if in case of merger and acquisitions it is referring to a complete company, part of it, or even if in case of a company reorganization or relocation, the policy is supportive to that case. In some regions, this may not be a policy, but an administrative procedure, but this may change in the future by means of a policy proposal. In the caser of inter-RIR, the counterpart RIR need to have a reciprocal policy or procedure that allows it. Finally, there should not be differences from the APNIC perspective, on the considerations of an M&A for different type of resources, because there is no reason for allowing, for example, IPv4 resources to be transferred, and instead IPv6 ones not. For example, an organization may be hosting services in a Data Center, by means of Virtual Machines and moving to a different DC in another region. It is ridiculous to allow to keep the IPv4 addresses (so not renumber the VMs) and instead ask to renumber IPv6. It is a big and unnecessary disruptive complexity. 2. Objective of policy change ------------------------------ To ensure that the policy text is clarified, if those cases are supported by the community. It will also facilitate companies or business units, moving or being established in other regions. It will minimize legal issues in case an acquisition claiming their rights over the acquired company and their existing assets (resources). 3. Situation in other regions ------------------------------ There is a variety of support of all those cases in different regions. The one more open is RIPE, followed by ARIN and LACNIC. A similar policy proposal is being discussed in AFRINIC. 4. Proposed policy solution ---------------------------- Actual Text 8.4. Mergers & acquisitions APNIC will process and record the transfer of IPv4 resources as the result of merger or acquisition. 11.0. Transfer of IPv6 resources APNIC will only recognize the transfer or IPv6 addresses as the result of Merger & Acquisition activity. The following conditions and consequences apply. 13.3. Mergers & acquisitions APNIC will recognize the transfer of ASNs as the result of merger or acquisition. Proposed Text 8.4. Mergers, acquisitions and relocations APNIC will recognize the transfer of IPv4 resources resulting from a partial or complete merger, acquisition, reorganization or relocation. In the case of inter-RIR, the counterpart RIR need to have a reciprocal policy/procedure that allows it. 11.0. Transfer of IPv6 resources APNIC will recognize the transfer of IPv6 resources resulting from a partial or complete merger, acquisition, reorganization or relocation. In the case of inter-RIR, the counterpart RIR need to have a reciprocal policy/procedure that allows it. 13.3. Mergers, acquisitions and relocations APNIC will recognize the transfer of ASNs resulting from a partial or complete merger, acquisition, reorganization or relocation. In the case of inter-RIR, the counterpart RIR need to have a reciprocal policy/procedure that allows it. 5. Advantages / Disadvantages ----------------------------- Advantages: Fulfilling the objectives above indicated and ensuring clarity on what is allowed and what not. The proposal makes clear that this may only happen, in case of Inter-RIR cases, when both RIRs have a reciprocal policy. Minimizing possible legal issues. Disadvantages: It could be considered that it can create further disaggregation, especially in IPv6, however, those cases are rare and only happening from time to time, so the impact is negligible, and justified by the documentation provided when the transfer is requested. In the Inter-RIR cases, coordination with the counter-part RIR is needed, but this is already an ongoing activity because all the regions (with the exception of AFRINIC), already have those mechanisms in place (for both, administrative and technical aspects). 6. Impact on resource holders ------------------------------ None. 7. References -------------- RIPE NCC: • https://www.ripe.net/publications/docs/ripe-682 ARIN: • https://www.arin.net/policy/nrpm.html#eight2 LACNIC: • https://politicas.lacnic.net/politicas/detail/id/LAC-2019-4/language/en • https://politicas.lacnic.net/politicas/detail/id/LAC-2019-3/language/en • https://politicas.lacnic.net/politicas/detail/id/LAC-2019-2/language/en