US/EU – Steps for Whois

My starting points

  1. Whois lookup is intended for both technical and functional purposes;
  2. A correct domain holder and the contacts need periodical verification;
  3. Regulations can work after narrowing down physical scenarios first;
  4. A sovereign country can do without a central gateway, accreditation authority and identity providers;
  5. Legal regulation, standardization of cost handling and technical specification may provide high availability and reliability;
  6. In Whois, business use of domains can be transparent without any individual privacy concerns;
  7. Fine-tuning at country level requires an adequate data structure first;
  8. Just like at the user level, technical personnel often deal passively with necessary actions;
  9. Technology-infused delivery of legal preparation isn’t too hard to achieve;
  10. When duties can be separated, separation can help, eg four eyes principle;
  11. A Whois tool that’s going to work requires to-do lists for all expertise.

How to correct web domain information with a registrar

List of ICANN-accredited registrars

Whois Data Reminder Policy (WDRP) for compliance

Querying databases that store the registered users or assignees of an Internet resource

Current iteration of the WHOIS protocol drafted by the Internet Society

Compare the uniform Database Language SQL – Structured Query Language


  1. issue: Registrars are pressed for tracing further data in legal matters.
    proposal: Opt, through a web ID that validates, for reference to country-level data;
  2. issue: Registries make verification work. A registry can decide on a domain holder name.
    Periodic verification is possible after entering a web ID.
    Strict verification, without any interpretation, is case sensitive and includes dots.
    Holder, holder name, registrar, registrar name, reseller and reseller name are relevant.
    Note: Eg Google Search provides a ‘google-site-verification’ value to put in the DNS.
    proposal: Opt for technical specification so that countries can realize data retrieval;
  3. issue: There are so-called ‘thick’ and ‘thin’ Whois servers, with one or two queries.
    proposal: If performance demands, choose one type of Whois server;
  4. issue: A field name such as ‘legal_address’ instead of ‘PostAddress’ can lead to discussion.
    issue: The DNSSEC field (suite of security extensions to the DNS) needs proper explanation.
    proposal: A definition and its explanation of fields that meet all needs are to-do and to address.


  1. issue: Use of the web ID to be introduced, should be restricted.
    proposal: US/EU lawyers agree how to define use of a fake web ID as forgery;
  2. issue: Search engines (like Google) publish search results from private web domains.
    issue: Search results are still published for a canceled domain.
    proposal: US/EU lawyers agree about publishing search results only if ‘web_publish y’;
  3. issue: A customer may register/renew through a registry for longer than one year.
    proposal: US/EU lawyers agree to register/renew for one year for realistic registration;
  4. issue: A registry can now decide unilaterally in a dispute with a registrar.
    proposal: US/EU lawyers try to improve handling of disputes;
  5. issue: A holder, registrar and registry do refuse to act on a spelling mistake.
    proposal: US/EU lawyers introduce a legal limitation in case of a misspelling;
    In The Netherlands eg ‘Vereniging van Registrars’ instead of ‘Vereniging Van Registrars’
  6. issue: Checking Whois for financial statements has not yet been analyzed as legal.
    issue: Segregation of duties of the contacts and answer time require attention too.
    proposal: US/EU lawyers update the analyzed six legal gTLD Whois purposes;
  7. issue: Direct responsibility and/or physical capability need a clear segregation of duties.
    need: A registry owns domains in its zone.
    need: A registrant holds a domain from a registry.
    need: A registry assigns a domain to a registrant and cancels it if necessary.
    need: Direct responsibility is limited to the lowest level of physical capability.
    need: Support must be able to attach a report by a third party to a customer account.
    need: An administrative contact responds to properly address any communication.
    need: One of the technical contacts responds to resolve a malfunction notification.
    need: A domain holder’s liability for harmful content and actions must be reasonable.
    proposal: US/EU lawyers work towards basic explanations in short sentences;
  8. issue: Privacy for admin-c is not a problem by using a specific functional email address.
    proposal: US/EU lawyers agree on admin_desk for legal matters, change of holder, etc.;
  9. issue: A reseller may have agreements such as to protect customer data.
    proposal: US/EU lawyers write generic reseller conditions (see eg the .nl zone);
  10. issue: Court decisions deal with issues with ownership aspects of web domains.
    need: A domain is kept out of liquidation if another intended registrant paid for it.
    need: Domains are included in the transfer of ownership of a company.
    proposal: US/EU lawyers introduce specific web domain regulation;
  11. issue: A web domain may contain confidential information from the previous holder.
    proposal: US/EU lawyers define moved data, similar to letter secrecy;
  12. issue: A country-level registry needs to start validating domain holdership.
    issue: A registrar can mask with an existing name such as ‘Privacy Protected by Hostnet’.
    need: The country-level registry provides a domain overview of a company behind its login.
    need: The country-level register provides a Whois check of a company behind its login.
    need: The country has a duty of care with regard to the correctness of the registered data.
    proposal: US/EU lawyers formulate a country’s legal basis for a web domain overview;
  13. issue: As for .eu, the countries in the European Union are not all countries in Europe.
    proposal: EU lawyers propose something like ‘EU Registry vzw’ instead of ‘EURid vzw’.

Fields and values

  1. issue: A hidden field name interferes with subsequent field checks.
    issue: An apparently hidden field value may in fact be registered.
    issue: Whois visibility becomes negotiable if physically limited to relevant scenarios.
    proposal: US/EU lawyers agree on a ‘held_back’ table field with SQL ready values.
    currently, five possible string values:
    ‘admin_desk, holder_name, business_use, legal_address’
    ‘holder_name, business_use, legal_address’
    ‘business_use, legal_address’

    after agreement regarding the web, seven possible string values:
    ‘admin_desk, holder_name, web_publish, web_id, business_use, legal_address’
    ‘holder_name, web_publish, web_id, business_use, legal_address’
    ‘web_publish, web_id, business_use, legal_address’
    ‘web_id, business_use, legal_address’
    ‘business_use, legal_address’

    Note: Readability of these values needs the spaces (filtered out in an SQL query).
  2. issue: Whois maintenance requires a data structure that fits the needs of IT processes.
    issue: After a change, clear logging of direct responsibility and/or physical access is required.
    proposal: US/EU lawyers agree on a last change field and its values.
    responsibility_types: ‘registry’, ‘registrar’, ‘reseller’, ‘registrant’
    last_name_change_by: responsibility_type, [name], [registry timestamp]
  3. issue: A web ID works effectively to verify a holder and one of the holder’s names.
    E.g. ‘’ of ICANN (incorporated, mutual-benefit nonprofit corporation ‘iCANN’).
    E.g. ‘’ in Whois for ‘.gov’ of organization ‘State of California’.
    With the many spelling mistakes, acceptance of auditing is still a long way off.
    Periodic verification of the actual holder name improves maintenance at a registry.
    proposal: Specify a web ID format, such as the IBAN bank account code.
    Registrars and domains (registrant and reseller) fields with a 34 character code, may have a two letter (ISO) country code, two digits for internal validation, ‘COMM’ and up to 26 characters within a country, such as ‘NL13COMM01234567890123456789012345’, in uppercase;
  4. issue: Verification needs statusses in Whois, including timestamp, retrieved from a history table at the registry.
    issue: The close match category ‘does almost match’ can only be determined by the country-level register.
    proposal: US/EU lawyers agree on Whois status fields and their values;
    web_id_status: no code, not consistent, not verified, does not exist, was valid, is valid
    holder_name_status: no code, does not match, does almost match, does exactly match
  5. issue: Reseller registration differs per TLD without standardization.
    proposal: US/EU lawyers may want to specify a reseller data structure.


  1. issue: Country-level web IDs are required to retrieve the holder.
    Country business registers can meet an important need.
    In The Netherlands, such registrations are moved to the Land Registry.
    Whether or not data is displayed is country specific.
    Lawyers can negotiate carefully at country level (not the EU).
    Shared sovereignty, as in the EU, would slow down negotiation.
    proposal: Country-level politicians agree on implementation of web IDs;
  2. issue: Country-level registers need to guarantee web IDs.
    Note: The Sarbanes-Oxley Act also took time for countries to adopt.
    proposal: Country-level registers will adopt a generic data structure;
  3. issue: A country-level register, such as KVK in NL, charges for solid lookups.
    proposal: Verification in a country-level register should become free of charge;
  4. issue: Country-level registers may charge for enabling web IDs.
    proposal: Verification costs for a country-level register must be indirect.


  1. issue: A regional server / application for Whois must function without centralization.
    A registry may need a layer around a legacy database structure.
    Search based on the web ID must be able to retrieve from each country-level register.
    Unicode works to handle all kinds of character sets worldwide.
    proposal: A roll-out application with Docker (is under construction by me);
  2. issue: The UK is not a valid domicile anymore to hold a .eu domain as former EU country.
    proposal: Such a change requires simple validation to check and maintain;
  3. issue: Registries may charge for a web ID enabled Whois application.
    proposal: Costs of a regional server / application must be indirect.

Cost handling

  1. issue: Economies of Scale cost advantages are achieved in both period and variable costs.
    proposal: An Economies of Scale cost advantage is only achieved in registrar’s period costs;
  2. issue: Legal updating at a registry can be a variable cost component equal to zero.
    proposal: Include updating details in annual costs and no longer pass on variable costs;
  3. issue: A registry looks over and manages its registrar’s information. Charging looks illegal.
    proposal: Include updating registrar details in period costs for a registrar;
  4. issue: Volume discount and direct debit discount for ‘.nl’ are called ‘expenses’ by SIDN.
    issue: Incentive programs for ‘.nl’ at SIDN up to 0.40 euro off the domain fee are significant.
    E.g. 8% volume discount from 100,000x and 2.5% direct debit discount at SIDN.
    proposal: Registries charge registrars with no discount;
  5. issue: Billing for a new or relocated domain is not cost-driven for the fiscal year.
    E.g. 0.60 euro for the first year at a domain provider for ‘.nl’.
    proposal: The fee for the first year of a domain is 6/12 of the renewal fee per year;
  6. issue: Customers unnecessarily commit for two or three years.
    proposal: Customers simply register and automatically renew for one year.