ICANN's Inter-Registrant Transfer (Change of Registrant) Policy
This policy affects any updates to the registrant name, organisation or email on any domains governed by ICANN. The idea is to prevent complaints with domain ownership by introducing further verification steps when a ‘material change’ is made to the registrant details. A ‘material change’ is considered any change to the registrant name, organisation or email address.
According to the policy both the old and new registrant need to verify the changes via email before it is processed. In addition to approving the change of details, the old registrant has the option to impose a 60 day transfer lock when they approve the change (think of it like a ‘cooling off period’ in which the domain name cannot be transferred to another registrar). So long as both parties approve the change the registrant contact information will be updated. If either party reject the change then the registrant contact information will not be updated and the request will essentially fail.
The policy also allows for wholesale partners to act as Designated Agents on behalf of their registrants to auto-approve changes on their behalf.
A Designated Agent is an entity with explicit authorisation from the old or new registrant to approve any changes to the registrant data on their behalf. This means the Designated Agent can automatically approve material changes to registrant data which ultimately means fewer emails need to be sent in the case of updates. Designated Agent status is enabled on all Synergy Wholesale partner accounts by default. This means that you will need to ensure a clause exists in your gTLD Registrant Agreement and/or other terms or policies, that warrants the domain name registrant gives you explicit permission to authorise any changes to the registrant data for domains on their behalf. This simply means that if there are any updates to the registrant contact data it will be processed immediately without the need for approval from any party. An example of such a clause can be something like:
“The domain name registrant explicitly confirms that <Company ABC Pty Ltd> will act as their Designated Agent in the event of any material change to domain name registrant data”.
It is important to note that in these circumstances a courtesy notification email will still be sent to the old and new registrant to advise them of the change to the registrant contact data.
What if I do not wish to be a Designated Agent?
If you do not wish to act as the Designated Agent, you will simply need to disable your Designated Agent status in the Synergy Wholesale system. You can find this information by hovering over you username in the top right hand corner and clicking ‘Account Options’ and then clicking the ‘Designated Agent’ tab. This means that when there is an update (material change) to the registrant contact data, the emails included below will be sent to the old and new registrant to approve the changes before the registrant contact data will be updated.
In order for a change in registrant data to processed (and the registrant data updated), both the old and new registrant must approve the changes (or the Designated Agent can approve it on their behalf and no email is required, however a courtesy ‘notification’ email is still sent to the old and new registrant).
If you choose to opt-out and disable your Designated Agent status through the Synergy Wholesale system, the following information will be included in the emails sent to the old and new registrant:
- The email to the old registrant will list the changes and give them the chance to approve or reject the changes. It will also give them the option to enable the 60 day transfer lock after the update.
- The email to the new registrant will list the information and give them the option to approve or reject the changes.
If either party rejects the changes the process will fail and the registrant data will not be updated. In the event an approval email needs to be resent it will resend to any party that has not yet approved the changes. This can be requested through the Synergy Wholesale system or via the Synergy Wholesale API. For example, if the old registrant has already approved the changes, the resend command will only email the new registrant (for their approval). Should the new registrant reject the changes, however, the entire process will fail and the registrant data will not be updated.
What about ID Protection?
As per the ICANN requirements Synergy Wholesale holds a copy of the Registrant, Admin, Technical and Billing contact data before the enabling of any ID protection. Because we are holding the original Registrant data we are determining that the enabling of ID protection is not considered a material change. This means that ID protection can be disabled and enabled without initiating the Inter-Registrant Transfer (Change of Registrant) process documented above. In the event that ID protection is disabled and registrant data is updated (either via the Synergy Wholesale system or API), the Inter-Registrant Transfer (Change of Registrant) process will commence.
Does this affect the WHOIS Data Verification?
Any changes to the registrant contact data, whether approved by the old and new registrant or automatically actioned (with the Synergy Wholesale partner acting as a Designated Agent) will still trigger the WHOIS Data Verification sequence, resulting in the supplied WHOIS contact data needing to be verified by the registrant contact or the domain name registrant may be suspended (and connected services will cease to function). For more information on this, please see our WHOIS Data Verification FAQ category.