EPDP Phase 2 – Registration Data Request Service Implementation


On 3 December 2021, Philippe Fouquart shared on the GNSO Council mailing list that the SSAD ODP Team is in the process of finalizing its analysis, including work related to the SSAD Cost Model. As such, and in connection with the Council’s request for a consultation (as captured in the Recommendations Report and elsewhere) with the ICANN Board related to concerns around financial sustainability, the next phase of that consultation will be scheduled in January 2022.

Ahead of the January consultation, an update session for the Council and GNSO appointed EPDP Team members was scheduled for 20 December 2021, focusing on the SSAD Cost Model information. During that meeting, the Council, GNSO appointed EPDP Team members, and GDPR Board Caucus members discussed the findings from the Operational Design Assessment (presentation) and the implications on the viability of the SSAD. On 4 January 2022, Philippe Fouquart shared a summary paper capturing the different ideas and suggestions that were made during that meeting. The Council scheduled a follow-on call on Wednesday 12 January 2022 to determine if there is convergence within the Council on possible next steps (see recordingpresentation as well as follow up email sent on 17th January 2022 with an updated SSAD ODP Next Steps document). While the Council received an early update, a general webinar on the SSAD ODP was held on 18 January 2022.

During its meeting on 20 January, the Council further considered procedural options (see slides), as well as the proposed approach for analyzing the ODA which is seen as an essential step before being able to make any determination about next steps. The Council considers that a small team of Council members with the support of EPDP Team representatives would be best positioned to analyze the ODA and provide guidance to the Council on possible next steps.

The Council met with the ICANN Board on 27 January (see recording) as the next step in its consultation related to concerns around financial sustainability of the SSAD. In advance of that meeting, the ICANN Board sent the GNSO Council a letter outlining some of its concerns as well as questions it hoped to receive input on from the Council.

At the request of Council, the small team considered the ODA and whether it had correctly interpreted the intent of the SSAD recommendations as well as provided its views on the concerns identified by the ICANN Board and potential options that could be considered. This resulted in a preliminary report to the GNSO Council, and following Council’s support for the preliminary report, an addendum in which the small team recommended and outlined a “proof of concept” approach to gather further data to help inform a decision on if/how to proceed with the SSAD recommendations. Following the Council’s support for this approach and request to the ICANN Board to proceed in this way, the ICANN Board directed ICANN org on 27 February to “proceed to develop and launch the System as soon as possible”. The ICANN Board also “directed ICANN org to continue to engage with the Phase 2 Small Team throughout the development and operation of the System, and ensure periodic publication of the collected usage data, once operational". As a result, this assignment form has been updated to reflect the Council's assignment to the small team during the implementation phase.


The small team is expected to engage with ICANN org throughout the development and operation of the System, and in particular consider:

  • The other topics identified in the addendum that the small team did not consider gating factors but for which it would be interested to have further discussions with ICANN org during the implementation phase to consider if/how some of these aspects could be considered to be added in the current implementation of WDS or a future version;
  • Success criteria for this System, which should include analysis of relevant usage data;
  • How to best to promote and secure comprehensive use of the system, both by potential requestors as well as ICANN accredited registrars.

In addition, the small team is expected to provide the Council with a recommendation on the approach and format through which, following implementation of the system, data should be reviewed and analyzed to help inform subsequent decisions on how to proceed with the SSAD recommendations.

Should there be disagreement within the small team on any of the above items, the lead of the small team is expected to consult with the GNSO Council for guidance. Furthermore, the lead is expected to provide regular updates to the GNSO Council on the status of work and timeline for implementation. This can be done in writing or through updates during Council meetings.  


The service is expected to be available within 11 months of adoption of the Board resolution. The small team is expected to work with ICANN org to identify the appropriate cadence of meetings to meet this timeline. In addition, the small team is expected to provide a recommendation to Council on the format and approach post-implementation prior to the launch of the system.  


The small team consists of interested Council members and EPDP Phase 2 members as well as the ICANN Board liaison to the EPDP Phase 2.

Note that the mailing list of the small team is publicly archived. Calls are recorded and accessible to observers.


EPDP Phase 2 Small Team Preliminary Report

EPDP Phase 2 Small Team Addendum

ICANN Board resolution

Whois Disclosure System Design Paper

Operational Design Assessment

EPDP Phase 2 Final Report


Next Steps



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