Dear colleagues, During RIPE 82, we provided you with an update on our observation of IPv6 stockpiling [1]. Based on the feedback we received and in preparation for the coming RIPE meeting, we would like to give you another update on that issue. According to the IPv6 Address Allocation and Assignment Policy, an LIR can receive up to a /29 IPv6 allocation without needing to supply any additional information. The RIPE community considered this size sufficient for most organisations for long-term IPv6 deployment. Additionally, LIRs may qualify allocations greater than /29 by submitting documentation that reasonably justifies this request [2]. However, over the past few years we have noticed that some organisations are collecting multiple IPv6 allocations in ways that are permitted by current RIPE policies but might conflict with the above-mentioned intent of the IPv6 policy. For example, it is possible for a single RIPE NCC member to receive a /29 allocation for each of the multiple LIR accounts that it holds. This is the result of a policy change in 2018 [3]. LIRs can also receive multiple IPv6 allocations via policy transfers without needing any further justification. However, when the IPv6 transfer policy was discussed in 2014, it was assumed that there wouldn't be an active transfer market [4]. We have gathered data showing the significant development of the collection of IPv6: - Almost 700 IPv6 allocations have been transferred in 2021 so far (and there have been more than 3,900 transfers since policy implementation in 2015) - About 60% all IPv6 allocations ever handed out by the RIPE NCC are now held as multiple allocations - In the last three months, more than 75% of all new allocations were given to members that already hold at least one IPv6 allocation - More than 1,500 members hold multiple IPv6 allocations, exceeding the size /29 - Almost 100 members hold more than 10 IPv6 allocations (the maximum is 102 IPv6 allocations held by one member) It is the RIPE NCC’s understanding that some of these situations are within the intent of previous policy changes, for example, to avoid renumbering of deployed IPv6 networks during holdership changes, or if a large company has multiple network departments that prefer to manage their own allocation. However, the huge volume indicates that most are for other reasons. While members can collect multiple IPv6 allocations without evaluation by the RIPE NCC, we still were able to gather some feedback how members plan to use their allocations. Many members simply stockpile them for an undefined future use, others plan to use them for activities which temporarily require a vast amount of IPs, and some plan to offer IPv6 on a large scale to other ISPs in their country. We believe that this situation could create several issues: - IPv6 might be deployed in conflict with RIPE policies, underlying RFCs and other best practices, resulting in challenges to that IPv6 deployment once the policy violation is discovered during an audit - There could be a negative impact on the quality of the registry if large parts of allocations were given to third parties without clear registration requirements - The policy requirement to justify larger IPv6 allocations would then be rendered useless If you agree that this is a problem, we would like to initiate a discussion in this Working Group about possible solutions. We see at least two potential paths forward. Firstly, if the Working Group believes that this trend is an indication of a widespread need for IPv6 address space larger than /29, then the requirement for justification could perhaps be adjusted for a larger allocation size. Members could then more easily get the address space they need, but as an aggregated block. Stockpiling would still be possible under this potential policy change, in fact on an even bigger scale. Secondly, if the Working Group believes that this trend is in conflict with the original intent of the IPv6 policy, adjustments to the policy can be proposed that give the RIPE NCC a stronger mandate to enforce it. One challenge here would be defining what IPv6 usages are considered within or outside of the intent of the policy and how to ensure better oversight without too much impact on IPv6 deployment. There might be other options that this working group can consider and discuss. If required, the RIPE NCC can provide additional information for this discussion. Kind regards, Marco Schmidt Registry Services Assistant Manager RIPE NCC [1] https://ripe82.ripe.net/presentations/7-RIPE82-Feeback-from-RS.pdf from slide 9 [2] https://www.ripe.net/publications/docs/ripe-738#initial_allocation [3] https://www.ripe.net/participate/policies/proposals/2018-01 [4] https://www.ripe.net/participate/policies/proposals/2014-12