That would not make them regulators because those are rules on the addresses themselves, which are services provided by the RIR.
Enforcing a certain type of abuse handling or prevention would be rules on the services addressed by the addresses, which are not part of the services provided by the RIR.
Arguably a proposal to simply require verification of the abuse mailbox does not make the NCC a regulator (and, in fact, I think the NCC already does this with ASNs), but I do not see how this would be an effective measure.
Making further requirements would make the NCC a regulator, and this may be dangerous precedent. Once this happens, there may be calls for additional regulation by the NCC, both from the community and governments, but also from third parties, and the NCC
is frankly not equipped to deal with this, nor is this desirable in my opinion. There could even be calls for the NCC to become responsible for enforcing certain EU regulations.
Regulation through supervision makes it much harder to enter an industry, and it is expensive for both the supervisor and the supervised. Our group is regulated by several governments for various functions in financial and professional services, as well
as for network operations - which, in some countries, require government supervision, and by ICANN (which, among other things, is an industry regulator) as a domain registrar, and I can tell you that the effort in dealing with supervisors alone is significant.
—
Maria Merkel
This email was sent by [company]. Any statements contained in this email are personal to the author and are not necessarily the statements of the company unless specifically stated.
Novecore and Staclar are collective trading names of Novecore Ltd., registered in England and Wales under company number 11748197, Novecore Licensing Ltd., registered in England and Wales under company number 11544982, Staclar
Carrier Ltd., registered in England and Wales under company number 12219686, Staclar Financial Services Ltd., registered in England and Wales under company number 13843292 (registered offices 54 Portland Place, London, UK, W1B 1DY); Novecore Professional Services
Ltd., registered in England and Wales under company number 13965912 (registered office 13 Freeland Park, Wareham Road, Poole, UK, BH16 6FA); Novecore (Estonia) OÜ, registered in Estonia under registry code 16543205 (local contact Baltic Business Services OÜ,
Narva mnt 5, 10117 Tallinn, Estonia); Novecore (USA) Inc., registered in Delaware under file number 6707907, Novecore Licensing (USA) LLC, registered in Delaware under file number 4030866, and Staclar, Inc., registered in Delaware under file number 7413401
(registered agents The Corporation Trust Company, Corporation Trust Center, 1209 Orange St, Wilmington DE 19801, USA). Novecore Licensing Ltd. is registered for VAT in the United Kingdom under VAT registration number 347 4545 80. Novecore (Estonia) OÜ is registered
for VAT in the European Union under VAT registration number EE102518979. Novecore Professional Services Ltd. is a trust or company service provider registered with and supervised by HM Revenue & Customs under the Money Laundering, Terrorist Financing and Transfer
of Funds (Information on the Payer) Regulations 2017 (registration number XMML00000178208). Staclar Financial Services Ltd. is an Annex 1 financial institution registered with and supervised by the Financial Conduct Authority under the Money Laundering, Terrorist
Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (firm reference number 989521). Registration is not equivalent to authorisation and is not an endorsement to do business with a firm. Staclar Financial Services Ltd. is not an authorised
person within the meaning of the Financial Services and Markets Act 2000 and does not review, approve, or endorse financial promotions for securities issues it is involved in or provide any form of investment advice.
