auDA submission to DNS Abuse Mitigation PDP 1 Initial Report

The DNS Abuse Mitigation PDP 1 Working Group sought Public Comment on its Initial Report. The Working Group was chartered by the GNSO Council to create an obligation for registrars to investigate other domains associated with a customer account or registrant where at least one domain is found to be engaged in DNS Abuse, as defined in the Registrar Accreditation Agreement (RAA).

The Working Group's initial report outlined a number of Preliminary Recommendations - auDA's comment and submission to the Initial Report can be found below.


Preliminary recommendationauDA response
Preliminary Recommendation 1Support Recommendation as written
Preliminary Implementation Guidance 1.1Support Implementation Guidance as written
Preliminary Recommendation 2Support Recommendation as written
Preliminary Recommendation 3Support Recommendation as written
Preliminary Implementation Guidance 3.1Support Implementation Guidance as written
Preliminary Recommendation 4Support Recommendation as written
Preliminary Implementation Guidance 4.1Support Implementation Guidance as written
Preliminary Recommendation 5Support Recommendation as written
Preliminary Implementation Guidance 5.1Support Implementation Guidance as written
Preliminary Recommendation 6Support Recommendation as written
Preliminary Implementation Guidance 6.1Support Implementation Guidance as written
Preliminary Recommendation 7Support Recommendation as written
Preliminary Recommendation 8Support Recommendation as written

Other comments

auDA welcomes the DNS Abuse Mitigation PDP1 initial report and supports its recommendations and implementation guidance as written.

We congratulate the working group on developing a workable proposal and consider it will be a valuable addition to the DNS abuse mitigation tool kit. As governments across the world increasingly focus on regulatory initiatives to strengthen online consumer protections and combat harms, the timely development and adoption of consensus policies that address challenges within ICANN’s remit is critical to demonstrate multistakeholder processes can achieve tangible outcomes.

We acknowledge that DNS abuse mitigation is not the sole responsibility of registrars, and that many may already be addressing DNS abuse through voluntary measures. Nevertheless, we believe establishing a positive obligation for registrars to proactively check associated domains is a meaningful contribution to strengthening the overall resilience of the DNS and increasing end user trust and confidence.

Overall, we consider the working group’s proposal provides a clear framework that is consistent with ICANN’s commitments and core values, and allows flexibility for the various registrar business models, the different jurisdictions they operate within and the unique circumstances of each investigation of potential DNS abuse.

We note that the proposal applies only to names that have been registered with malicious intent and explicitly excludes compromised domains. In our experience, reports of DNS abuse often involve domains associated with compromised websites. For more on this, we refer to our comments on the Preliminary Issues Report submitted in October 2025.

We encourage registrars to view the recommendations as a minimum baseline and, in accordance with applicable law and internationally recognised privacy principles, to consider voluntary action to reduce risk to others when they discover cases of DNS abuse that are due to compromise. This could include, for example, working with registrants or resellers to ensure software is updated or to review other domains that may be sharing a common webserver software environment.

Mitigating DNS abuse is a collective responsibility. auDA is committed to minimising abuse in the .au ccTLD to keep it trusted and secure. We welcome ongoing collaboration with all stakeholders in the ecosystem to share experiences and best practices in abuse mitigation and look forward to engaging in further community discussions on this issue.

Summary of Submission

auDA supports the recommendations in the initial report and congratulates the working group on developing a clear framework that will be a valuable addition to the DNS abuse mitigation tool kit.

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