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prop-164-v002 - Impact Asessment
Published: 15 August 2025
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1. APNIC’s Understanding of the Proposed Policy

This Proposed Policy aims change the minimum allocation size of IPv6 prefixes from /32 to /36. The proposer has indicated that this is to provide more accurate data for sub-assignment of these resources.

Changes would be required to APNIC-127 if this proposal reaches consensus.

The Secretariat notes the following points:

    The current policy text under ‘5.2.3.1 LIR-to-ISP allocation’ mentions how LIRs can sub-allocate IPv6 to their subordinate ISPs, suggesting IPv6 sub-allocations should be made to the LIRs downstream ISPs (who are connected to them). The updated text does not reference the term ‘subordinate ISPs’

        Add a new line that reads: “When an LIR makes a delegation to an ISP”

This could be interpreted as LIRs can make sub-allocations to any ISPs regardless if they are connected with that LIR or not.

    Consideration needs to be made on the impact of existing allocations and whether Resource Holders can “Return” the balance of their /32 so that they only hold a /36, as the authors have not made it clear is this is a situation they have considered.

    The authors also need to consider consistency of language (ie: allocation/assignment/delegation

Clarification would be required from the authors on the above 3 points prior to editorial changes and call for comment.

2. Impact of Proposed Policy on Registry and Addressing System

As at 14th August 2025, there are 3095 Resource Holders that would potentially qualify for this change.
This may create an increased workload on the Member services team in processing these requests as we would anticipate that the IPv6 Assignments would be returned in exchange for a /36 allocation

We don’t believe that this will create further fragmentation in the global routing table. The currently announced assignments would be replaced with the allocated address space

3. Impact of Proposed Policy on APNIC Operation/Services

Changes would be required within APNIC systems to reduce the minimum allocation size in front and back-end systems

4. Legal Impact of Proposed Policy

No Legal impact identified

5. Implementation

Changes in the policy text(APNIC-127) would need to be processed as per APNIC’s Document Editorial Policy(APNIC-112)

There will be several systems changes required to core registry and resource systems.

Implementation time frame would be 6 Months subject to the call for editorial comments period.