Yesterday I attended a round-table for Nominet’s revised proposal for allowing registrations directly under the .uk domain. The original proposal last year received a great deal of feedback and Nominet have responded with a much simpler second version, described in a consultation document and background paper. It was clear from the discussion that not everyone is convinced that second level registrations should be allowed at all, however my concern is that if it does go ahead the opportunities for it to cause problems should be minimised. I’ll be responding formally to the consultation in September: comments and suggestions for that response are very welcome. You're also welcome to respond direct to Nominet, of course.

The following summarises the main areas of discussion:

Security

The original proposal would have required all new second level domains to implement specified security features, in particular DNSSEC and scanning for malware. Most responses seem to have agreed that these should be promoted, but to have been concerned that making them mandatory for new domains was both impractical and would damage the reputation of existing .uk domains which might already have equivalent or better security measures. Nominet have therefore decided to detach the security strand and work with partners on promoting and developing domain security measures that would be available to all .uk domains. This also means that the suggested price for a second level domain will be considerably less than in the original proposal.

Registrant Validation

There is a worldwide concern to improve the quality of information about registrants, in case of problems, but this creates tensions with both privacy and the desire to be able to register domains quickly and simply. It appears (though I don’t think this is explicitly stated in the consultation) that individual registrants will be still able to conceal their personal information as they can for current .uk registrations. For all second-level registrations Nominet are proposing to validate the supplied postal address details against on-line databases, and to verify that the supplied e-mail address can be used to contact the registrant. Registrants from outside the UK will be required to provide an address in the UK where legal documents can be served. These checks will be done in parallel with the creation of the domain: the domain may be delegated before the checks complete, but if checks fail then it will be suspended.

Nominet are proposing to allow existing third level registrants to request these checks for a nominal fee, for second level domains this would be included in the registration fee.

Comments at the round-table were that that to improve trust in the .uk namespace the checks ought to be made mandatory across the whole domain, or even registration within the domain restricted to UK residents or registered businesses only.

Rights to domains

The original proposal involved a multi-stage launch process for the new domain, similar to that used for ICANN’s launch of new generic top level domains. Following the consultation it has been concluded that this was unnecessarily complex, given that what is proposed is an extension of an existing domain where many rights issues have already been resolved. The new proposal is that where a domain already exists in one (or more) of the hierarchies operated by Nominet (eg example.org.uk), those registrants would have six months to decide if they wanted the equivalent example.uk domain. Nominet are planning to contact all existing registrants to try to ensure that all are aware of this opportunity. Domains that don’t exist elsewhere in .uk can be registered at the second level immediately, on Nominet’s usual first-come, first-served basis. If more than one existing registrant requests the new domain it would go to the registrant whose third level domain had been continuously registered for longest. If that domain is currently being challenged under a dispute resolution process then the allocation of the new domain will be delayed until the challenge is resolved. It’s not yet clear how domains that aren’t managed by Nominet - such as .ac.uk, .gov.uk, .nhs.uk and police.uk - will be able to participate in this process. Nominet are planning to talk to Janet and others concerned in those domains (and .sch.uk which has never allowed normal registrations). They are also seeking views on how the transition could be made easier – for example should there be a discount for those holding both domains in a ‘pair’, a longer window for existing domain holders to transition, etc.?

Comments included a suggestion that the .co.uk domain should simply be moved en masse to .uk, and, conversely, warnings of the rebranding (and possibly reputation re-building) costs for any business that did move! It was also pointed out that using time of registration was unfair to registrants of two-letter domains in both .co.uk and .org.uk, since those were released and auctioned relatively recently so registrants did not control the order in which they happened to be created.

Something that wasn’t discussed, but which I will be putting in our response, is whether certain domains should be reserved. For the .uk proposal Nominet have a very short list of domains that will not be created (the main ones being the headaching uk.uk and com.uk). A number of .gov.uk domains which will not be moving to www.gov.uk (e.g. royal.gov.uk) will also have their second-level equivalents reserved. In our response to the original proposal I pointed out the risk of confusion if parallel hierarchies could be created, especially as these would not be covered by the normal dispute resolution processes. So as well as .com.uk I’d also see .edu.uk, .limited.uk and several others as more likely to do harm than good. Nominet’s proposals for .wales and .cymru do include reserving various generic terms so I’ll be recommending that they consider taking the same approach to .uk

Search Engine Results

One problem highlighted in responses to the original consultation was that organisations that moved domain might lose their accumulated reputation with search engines. Nominet are discussing this at high level with Google; apparently there have a ‘change of address’ function that should preserve reputation etc. across the change.