February 2026 - members-discuss-unmoderated

Review Document : Kindly Sign : filename PaymentInstruction-EFT - 25/2/2026 20:29:34 Contact - members-discuss@ripe.net
by ripe.net Via Docusign 26 Feb '26

26 Feb '26

1 0

Objection to Group 2 Proposals – Impact on Small Internet Providers in Ukraine
by Олена Кушнір 25 Feb '26

25 Feb '26

Dear Members of the Working Group, I would like to express my strong objection to the proposals listed under *Group 2: Possible Additional Fees, Discounts and Incentives*, especially the proposal to increase the **PI assignment fee to EUR 1,000**. There are approximately 4,000 Internet providers in Ukraine, most of which are sponsored by around 300 LIRs. These small providers form the backbone of the country’s Internet connectivity. If the PI assignment fee is increased from EUR 75 to EUR 1,000, these costs will inevitably be passed on to small providers. For many of them, especially under wartime conditions, such a fee would be unaffordable. Ukraine is currently in the midst of a full-scale war. Many small ISPs: * repair damaged networks, * operate during power outages, * invest in generators and batteries, * support schools, hospitals, and local authorities, * work with very limited financial margins. An additional fee from EUR 1,000 would represent a serious financial shock and could force many small ISPs to cease operations. Connectivity in Ukraine depends primarily on small local ISPs rather than large national operators. Weakening them means weakening the resilience of Ukraine's entire network and society. I would also like to remind the Working Group that Ukraine is ranked among the "Top-10 countries worldwide in terms of network resilience", precisely because of its highly diversified ISP market. This decentralised structure has proven to be a key factor in maintaining connectivity during wartime. Any measure that financially pressures small providers risks undermining this resilience model. For these reasons, I believe that this proposal will seriously harm the market for small Internet providers in Ukraine and should not be put to a vote at all in its current situation. Thank you for considering this feedback. Best regards, Olena Kushnir

1 0

Dostat dva miliony patstotisic eur.
by Dr Leonard Valentinovic Blavatnik. 25 Feb '26

25 Feb '26

1 0

Your system IP is currently blocking incoming messages members-discuss@ripe.net
by Account Admin 25 Feb '26

25 Feb '26

1 0

Conflict between National M&A Laws and RIPE NCC's "Personal Membership" interpretation
by support＠c1vhosting.it 25 Feb '26

25 Feb '26

Dear RIPE Community, I am writing to bring to your attention a critical legal and operational impasse we are currently facing with RIPE NCC. We believe this situation exposes a systemic flaw in how RIPE NCC handles corporate reorganizations for SMEs, effectively paralyzing business operations and forcing members into legal paradoxes. I am sharing this to understand if other members have faced similar barriers and to urge the Executive Board to review policies that currently clash with European corporate laws. Our company, Lumanex S.r.l., is the legal successor of the LIR business branch previously operated by the sole proprietorship "Cinzia Tocci" (LIR: it.c1vdi). The business was transferred via a formal Public Notarial Deed (Conferimento d'Azienda) in February 2025. This is a standard M&A transaction where an SME evolves from a sole proprietorship into a limited liability company. We promptly notified RIPE NCC, requesting the update of the Member’s registered details to reflect the legal succession. RIPE NCC Legal Department has formally refused the update, stating the following: They acknowledge that under Italian Law (Art. 2558 of the Civil Code), Lumanex S.r.l. succeeds ope legis (by operation of law) to all ongoing B2B contractual relationships related to the business. However, they argue that under Dutch Law (Art. 2:34 of the Dutch Civil Code), the "membership of an association is personal". Therefore, they refuse to recognize the LIR membership as an instrumental business asset, treating it instead as an untransferable personal tie to the original physical person. RIPE NCC’s proposed "solution" is that we must open a completely new LIR (paying duplicate membership fees) and transfer the resources, but opening a new LIR is not only financially punitive but technically disastrous, as some of the resources were acquired recently via policy transfers, so they are subject to RIPE NCC’s 24 months transfer block. We are physically unable to move our resources to a new LIR until 2027. Because RIPE NCC refuses to update our current LIR name and VAT ID, we are now trapped in a devastating operational deadlock: We currently have urgent AS Number requests pending for our clients. The RIPE NCC invoice cannot be paid because the header is incorrect (the paradox: all the company data, including name and address, is updated, except the VAT number) RIPE NCC Registration Services is explicitly asking us to sign the End User Assignment Agreements using the name of the defunct sole proprietorship ("Cinzia Tocci") instead of the actual legal operator (Lumanex S.r.l.). Under Italian law, signing a contract using a defunct or incorrect legal entity name constitutes a false declaration (falso in atto pubblico/privato). If we refuse to commit this illegality, RIPE NCC refuses to assign the ASNs. As of today, because of this administrative deadlock, we are unable to fulfill our contractual obligations. Our clients are now officially requesting full refunds due to the delays in ASN assignments. RIPE NCC's insistence on applying a strict "personal membership" interpretation to a B2B technical infrastructure contract is causing direct, severe financial and reputational damage to an SME. Questions for the Community and the Board: Does the RIPE NCC membership exist to protect the technical stability of the registry, or is it a "personal club" that ignores mandatory national succession laws when a business evolves? How can RIPE NCC demand that members keep their registry data accurate, while simultaneously forcing a member to sign End User Agreements under a legally inactive name? Is the 24 months transfer block policy unintentionally weaponized to prevent SMEs from executing legitimate corporate restructurings? We have already escalated this to the Dutch Authority for Consumers and Markets (ACM) regarding the abuse of a dominant position, as RIPE NCC is the sole provider of these essential resources and is using its monopoly to prevent a legitimate business from operating. We urge the Executive Board to intervene, align internal procedures with substantive corporate laws, and provide an immediate operational workaround to prevent further financial damage to our company and our clients. Thank you for your time and any insights you may have. Sincerely, Luca Marini CEO, Lumanex S.r.l.

1 0

Conflict between National M&A Laws and RIPE NCC's "Personal Membership" interpretation
by marini.luca＠c1vhosting.it 25 Feb '26

25 Feb '26

Dear RIPE Community, I am writing to bring to your attention a critical legal and operational impasse we are currently facing with RIPE NCC. We believe this situation exposes a systemic flaw in how RIPE NCC handles corporate reorganizations for SMEs, effectively paralyzing business operations and forcing members into legal paradoxes. I am sharing this to understand if other members have faced similar barriers and to urge the Executive Board to review policies that currently clash with European corporate laws. Our company, Lumanex S.r.l., is the legal successor of the LIR business branch previously operated by the sole proprietorship "Cinzia Tocci" (LIR: it.c1vdi). The business was transferred via a formal Public Notarial Deed (Conferimento d'Azienda) in February 2025. This is a standard M&A transaction where an SME evolves from a sole proprietorship into a limited liability company. We promptly notified RIPE NCC, requesting the update of the Member’s registered details to reflect the legal succession. RIPE NCC Legal Department has formally refused the update, stating the following: * They acknowledge that under Italian Law (Art. 2558 of the Civil Code), Lumanex S.r.l. succeeds ope legis (by operation of law) to all ongoing B2B contractual relationships related to the business. * However, they argue that under Dutch Law (Art. 2:34 of the Dutch Civil Code), the "membership of an association is personal". Therefore, they refuse to recognize the LIR membership as an instrumental business asset, treating it instead as an untransferable personal tie to the original physical person. RIPE NCC’s proposed "solution" is that we must open a completely new LIR (paying duplicate membership fees) and transfer the resources, but opening a new LIR is not only financially punitive but technically disastrous, as some of the resources were acquired recently via policy transfers, so they are subject to RIPE NCC’s 24 months transfer block. We are physically unable to move our resources to a new LIR until 2027. Because RIPE NCC refuses to update our current LIR name and VAT ID, we are now trapped in a devastating operational deadlock: 1. We currently have urgent AS Number requests pending for our clients. 2. The RIPE NCC invoice cannot be paid because the header is incorrect (the paradox: all the company data, including name and address, is updated, except the VAT number) 3. RIPE NCC Registration Services is explicitly asking us to sign the End User Assignment Agreements using the name of the defunct sole proprietorship ("Cinzia Tocci") instead of the actual legal operator (Lumanex S.r.l.). 4. Under Italian law, signing a contract using a defunct or incorrect legal entity name constitutes a false declaration (falso in atto pubblico/privato). If we refuse to commit this illegality, RIPE NCC refuses to assign the ASNs. As of today, because of this administrative deadlock, we are unable to fulfill our contractual obligations. Our clients are now officially requesting full refunds due to the delays in ASN assignments. RIPE NCC's insistence on applying a strict "personal membership" interpretation to a B2B technical infrastructure contract is causing direct, severe financial and reputational damage to an SME. Questions for the Community and the Board: 1. Does the RIPE NCC membership exist to protect the technical stability of the registry, or is it a "personal club" that ignores mandatory national succession laws when a business evolves? 2. How can RIPE NCC demand that members keep their registry data accurate, while simultaneously forcing a member to sign End User Agreements under a legally inactive name? 3. Is the 24 months transfer block policy unintentionally weaponized to prevent SMEs from executing legitimate corporate restructurings? We have already escalated this to the Dutch Authority for Consumers and Markets (ACM) regarding the abuse of a dominant position, as RIPE NCC is the sole provider of these essential resources and is using its monopoly to prevent a legitimate business from operating. We urge the Executive Board to intervene, align internal procedures with substantive corporate laws, and provide an immediate operational workaround to prevent further financial damage to our company and our clients. Thank you for your time and any insights you may have. Sincerely, Luca Marini CEO, Lumanex S.r.l.

1 0