How to be a 100% ICANN Compliant Domain Registrar?

Venkatesh Venkatasubramanian
2 days ago
4 min read

ICANN compliance roadmap for domain registrars – explained by consultant Venkatesh Venkatasubramanian

Running a domain registrar that is truly ICANN-compliant is not just about getting accredited and moving on. Compliance is an ongoing discipline that touches every part of your operations — from how you collect customer data to how you handle abuse complaints. Many new registrars underestimate this, and many established ones get notices simply because they don’t align their daily operations with what the Registrar Accreditation Agreement (RAA) actually demands.

This article breaks down what a registrar must do — continuously, accurately and consistently — to be considered “100% ICANN compliant” in real-world terms.

Understanding What ICANN Actually Expects

ICANN’s expectations are defined primarily by the Registrar Accreditation Agreement (RAA) and the consensus policies that apply to all registrars. These include the Registration Data Policy, the Transfer Policy, UDRP, ERSR procedures, Whois/RDAP requirements, and more.

Compliance is not judged by what you intend to do, but by what your systems, website and staff actually do every day.

ICANN Contractual Compliance does three things continuously: monitors registrars, investigates complaints and conducts periodic audits. If something is out of place — a missing abuse contact, incorrect RDAP output, expired policy on your website — ICANN flags it immediately.

Laying the Foundation Inside Your Registrar

A registrar that aims to stay compliant needs internal structure. ICANN expects you to have responsible contacts, documented procedures, and trained staff. When ICANN audits you, they check not just what you claim, but whether you have real evidence: your policies, logs, sample tickets, screenshots, RDAP output, reseller agreements, and internal training records.

A registrar that cannot demonstrate how it verifies data, how it handles abuse, how it manages resellers, or how it manages transfers is simply not compliant — regardless of whether it “means well.”

Compliance is about documentation as much as execution.

Registration Data and RDAP: The Most Scrutinised Area

The biggest source of ICANN complaints globally is registration data. To remain compliant, a registrar must collect, validate and verify the data required under the RAA and Registration Data Policy. Email verification failures must be handled properly. Accuracy complaints must be investigated, and unresolved inaccuracies must lead to suspension.

RDAP output must remain accurate, available and consistent with ICANN requirements. Even if privacy laws apply, the data you retain internally must still meet RAA and policy-level requirements.

The updated Registration Data Policy also revises certain retention rules. While some legacy RAA retention obligations still stand, the new policy reduces retention for specific data to 15 months. Registrars must adjust their systems accordingly and, where local law conflicts, apply for an ICANN data-retention waiver instead of ignoring the requirement.

Abuse Handling: The Fastest Way to Get a Notice

ICANN takes DNS abuse extremely seriously. A compliant registrar must publish a properly functioning abuse contact, monitor it, and respond in a timely manner. This includes reviewing phishing, malware, botnet, spam or illegal-content reports and taking proportionate action.

ICANN doesn’t expect you to be a law-enforcement agency, but it expects you to investigate every valid report, communicate with reporters, and document your decisions. Registrars that ignore abuse tickets or delay responses are the first to receive breach notices. A good registrar always has an internal SLA for abuse handling — even if it’s not published externally.

Resellers: The Hidden Compliance Weak Point

One of the biggest surprises for many registrars is that ICANN holds the accredited registrar responsible for everything a reseller does. If a reseller’s website misrepresents domain pricing, violates ICANN policy, fails to publish key notices or handles customer data incorrectly, ICANN comes to you — not the reseller.

To stay compliant, a registrar must supervise its resellers, enforce ICANN-required clauses in reseller agreements, and take action against habitually non-compliant partners. Many registrars get into trouble because they treat resellers casually. ICANN does not.

Doing the Basics Right: Renewals, Expiry Notices and Transfers

Much of registrar compliance comes down to basic operational hygiene. Expiry notices must be sent on time. Grace periods must be honoured. Auto-renew and refund behaviour must follow the TLD’s lifecycle rules. Transfers must follow the Transfer Policy exactly — secure auth-codes, clear approval flows, and fair handling of transfer locks.

ICANN frequently receives complaints about “domain not renewed,” “domain deleted too early” or “registrar denying transfer without a valid reason.” These operational mistakes are easily avoidable, yet they account for a huge volume of registrar issues. A registrar that follows ICANN’s lifecycle rules precisely rarely faces problems.

Working with ICANN Contractual Compliance

The healthiest registrars treat ICANN Compliance as a partner instead of a threat. Complaints will come — even the largest registrars get them daily. Compliance is judged on how well you investigate, resolve and document these issues.

When ICANN sends a notice, they expect clear, timely, evidence-based responses. Registrars that answer professionally and fix underlying problems build strong relationships. Registrars that delay, ignore or provide incomplete answers escalate into breach notices. A registrar that keeps its policies updated, responds to ICANN promptly, and maintains clean evidence trails stays safe — consistently.