Implement 2026 ICANN Transfer Policy changes once effective

[getpinga]

Summary

ICANN adopted the Transfer Policy Review recommendations in June 2026, but they should not be treated as current contractual requirements until ICANN publishes the revised Transfer Policy and its effective date.

Track and implement the required changes once the revised policy becomes effective.

Current/authoritative Transfer Policy page:
https://www.icann.org/en/contracted-parties/accredited-registrars/resources/domain-name-transfers/policy

ICANN Board adoption of the Transfer Policy Review recommendations:
https://www.icann.org/en/board-activities-and-meetings/materials/approved-resolutions-regular-meeting-of-the-icann-board-07-06-2026-en

Required changes when effective

• Replace the current Losing Registrar FOA with the new Transfer Confirmation requirements.

  • Include the gaining registrar IANA ID and link to ICANN's accredited registrar list.
  • Support English plus the language of the registration agreement when different.
  • Express the default approval period as 120 hours.
  • Do not provide an immediate-approval mechanism if prohibited by the final effective policy.

• Implement the new TAC lifecycle requirements.

  • Generate/set TAC only when requested.
  • Provide the TAC within the policy-defined maximum period.
  • Use policy-compliant secure/random TAC generation.
  • Enforce the required TAC lifetime.
  • Enforce one-time use/reset behavior.

• Add the TAC Issued notification to the registrant within the policy-defined delivery window.

• Add the mandatory Transfer Completion notification from the losing registrar.

  • Send within the policy-defined delivery window after completion.
  • Use the registrant contact information captured at the time the transfer request was received.
  • Include domain name, gaining registrar/IANA ID, completion timestamp/time zone, and required dispute/contact information.

• Implement the revised post-registration and post-transfer restriction periods, including any permitted documented exceptions defined by the final policy.

• Remove/avoid any obsolete Gaining Registrar FOA workflow if the final effective policy eliminates it as adopted.

Namingo implementation notes

The existing architecture should be extended rather than replaced:

• automation/epp_poll.php remains the registry poll collector.
• automation/transfer_notify.php should handle Transfer Confirmation and Transfer Completion notifications.
• TAC issuance is a local registrar action and therefore needs a shared backend event/audit path rather than relying only on EPP poll messages.
• WHMCS, FOSSBilling and Loom should continue using the common automation/backend abstraction rather than platform-specific compliance hooks.
• Preserve immutable audit evidence for all policy notifications, including recipient snapshot, subject/body, source event, registry message ID where applicable, and sent timestamp.

Activation condition

Do not implement these recommendations as mandatory behavior merely because they were adopted by the ICANN Board.

Implementation should begin when ICANN publishes the revised consensus Transfer Policy, implementation requirements, and effective/enforcement date. Before merging, verify the final operative text against the authoritative policy page above, because details may differ from the adopted recommendations during implementation.