________________________________________________________________________ prop-050-v001: IPv4 address transfers ________________________________________________________________________ Author: Geoff Huston gih@apnic.net Version: 1 Date: 26 July 2007 1. Introduction ---------------- This is a proposal to remove APNIC policy restrictions on the transfer of registration of IPv4 address allocations and IPv4 portable address assignments between current APNIC account holders. This proposal is a refinement of the historical resource transfer policy and applies to IPv4 resources held by current APNIC account holders. 2. Summary of current problem ------------------------------ Current APNIC policies relating to the registration of transfer of address holdings limit the eligibility of registration of transfers to those relating to mergers and acquisitions of entities that are administering an operational network. It is currently anticipated that the IPv4 unallocated address pool will be exhausted in a timeframe of between 2009 and 2011. There is a very considerable level of investment in IPv4-based services in the Asia Pacific region, and a transition to IPv6-based service delivery is likely to take longer than the remaining period of unallocated address availability. Accordingly, it is likely that demand for IPv4 addresses will continue beyond the time of unallocated address pool exhaustion, leading to a period of movement of IPv4 address blocks between address holders to meet such continuing demand for IPv4 address blocks. It is the objective of the APNIC IPv4 address registry to accurately record current address distribution information. This proposal advocates that APNIC recognise the transfer of IPv4 addresses between current APNIC account holders, and places some constraints on the parties to the transfer as a precondition for the registration of the IPv4 address transfer to be undertaken by APNIC. 3. Situation in other RIRs ---------------------------- It is the understanding of the proposer that no comparable IPv4 resource transfer policy between account holders has been adopted in any other RIR. 4. Details of the proposal ---------------------------- APNIC will process IPv4 address transfer requests following the adoption of this proposed policy, subject to the following conditions: Conditions on the IPv4 address block: - Only IPv4 address blocks equal to, or larger than, a /24 prefix may be transferred. - The address block must be in the range of addresses administered by APNIC, either as part of a /8 address block assigned by the IANA to APNIC, or as part of a historically-assigned address block now administered by APNIC. - The address block must be allocated or assigned to a current APNIC account holder. - The address block will be subject to all current APNIC policies from the time of transfer. This includes address blocks previously considered to be "historical". Conditions on source of the transfer: - The source entity must be a current APNIC account holder. - The source entity must be the currently registered holder of the IPv4 address resources, and not be involved in any dispute as to the status of those resources. - The source entity will be ineligible to receive any further IPv4 address allocations or assignments from APNIC for a period of 24 months after the transfer. - In making any future IPv4 address resource requests to APNIC, for as long as IPv4 address resources are available from APNIC, following the expiration of this 24 month ineligibility period, the source will be required to document the reasons for the IPv4 address resource allocation. Conditions on recipient of the transfer: - The recipient entity must be a current APNIC account holder. - The recipient entity of the transferred resources will be subject to current APNIC policies. In particular, in any subsequent APNIC IPv4 address allocation request, the recipient will be required to account for all IPv4 address space held, including all transferred resources. - APNIC fees payable by the recipient will be assessed on the basis of all resources held. The address transfer process: After APNIC is notified of the transfer by both the source and the recipient of the transfer: 1. APNIC will update the registration records relating to the transferred addresses. 2. APNIC will adjust the source's address holdings as of the date of transfer. In terms of membership and/or service fee calculations this shall be processed in the same manner as a return of address holdings to APNIC as of that date. 3. APNIC will adjust the recipient's address holdings to include the transferred addresses as of the date of the transfer. In terms of membership and/or service fee calculations this shall be processed in the same manner as an allocation or assignment of address holdings to the recipient as of that date. 4. The following transfer details will be published by APNIC in a public log of resource transfers: - Source - Recipient - Address resources - Date of transfer Transfer fees: APNIC may charge the recipient a service fee on the transfer transaction. The transfer service fee may vary according to the total size of the address block being transferred. The transfer fee schedule shall be set initially by the APNIC Executive Council upon adoption of this policy. The transfer fee schedule will be included as part of any future review of APNIC fees and charges. 5. Advantages and disadvantages of the proposal ------------------------------------------------- Advantages: This proposal would: - Ensure that the APNIC registry continues to reflect the current actual status of IPv4 resource holdings by APNIC account holders. - Mitigate the risks to the integrity of the network and its routing and addressing infrastructure associated with the unregistered transfers of IPv4 addresses. This proposal, by acknowledging the existence of address transfers and registering the outcomes would ensure that the APNIC address registry continues to maintain accurate data about resources and resource holders. The proposal also ensures that those parties who currently rely on the accuracy of this registration information can continue to rely on the currency and accuracy of this information in good faith. - Provide a stronger incentive for unused IPv4 address space to return to active use, helping to satisfy residual demand for IPv4 address space across the IPv6 transition. Disadvantages: - Concerns have been raised about a market-based system emerging as the only means to obtain IPv4 address space in future, and the potential for certain forms of market failures, including the possibility of hoarding, speculation and price manipulation. A number of factors mitigate these risks. As the transition to IPv6 gathers pace, a market-based value of IPv4 addresses would fall in line with the decreasing value proposition of IPv4-based services in an increasing IPv6 network. An additional constraint would apply if this policy were to be adopted while IPv4 addresses are still available from APNIC, as APNIC's established IPv4 address allocation process would continue to provide an alternative source of supply of IPv4 addresses to the industry. 6. Effect on APNIC members ---------------------------- APNIC members will have the ability to register the transfer of IPv4 address resources between APNIC account holders. 7. Effect on NIRs ------------------- This policy does not encompass IPv4 address holdings administered by NIRs, nor the transfer of resources where the source or recipient are NIR-serviced entities.