Dear colleagues, I would like to open a discussion in connection with the email delivered today (Charging Scheme Model Consultation: Phase 2). To be honest at the outset: I usually try to ignore matters around RIPE, pay the annual fee, and not pay much attention to it, as the whole thing strikes me as absurd. This time, however, I feel compelled to respond. I make no secret of my opinion that the current RIR model is, in 2026, obsolete. IPv4 address space has been exhausted (which is, incidentally, the fault of the RIRs themselves, who in the past often allocated IP addresses inefficiently while collecting millions for their operations), IPv6 is (according to everyone) “infinite,” and ASNs are, and most likely always will be, sufficient in number. I therefore respectfully ask whether we truly need an organization with an annual budget of EUR 40 million to serve approximately 20,000 active LIRs. *** Regarding the new scheme itself, I have several objections and uncertainties. New Member Sign-up Fee – RIPE signs identical contracts with all members, which it undoubtedly generates based on the provided information. Concluding the contract involves verifying the entity, signing the agreement, and activating the account. What on earth costs an incredible EUR 1,000 here? I assume RIPE is a non-profit organization, so this is not meant as “super business.” In my view, the trend should be the exact opposite: that “anyone” can set up their own LIR, obtain genuinely their own IPv6 addresses, under conditions that are closer to cost-based. Who on earth would want—on top of a large annual fee—to also pay EUR 1,000? Additional LIR Account Fee – this apparently assumes that there are entities that have or want multiple LIRs. Those I know solved this by setting up another company (which, incidentally, costs significantly less to establish than EUR 500). Perhaps RIPE has different data, but I believe these accounts were created solely to gain access to IPv4 while it was still available. That no longer interests anyone today. IPv4 Waiting List Sign-up Fee – sorry, but is this meant seriously? Yes, I certainly welcome the “separation” of the sign-up fee (which RIPE already has as one of the highest among all RIRs) and IPv4. Given that the plan mentions no transitional provisions, I assume that those already on the waiting list will remain there, meaning that those who pay will simply join the queue behind them. All this in a situation where we all know that the chance of actually receiving IPv4 addresses asymptotically approaches zero (or they might receive them in several years). In reality, this is a bet on speculation, because if they need the addresses, they must buy them elsewhere anyway—or is someone supposed to wait ~3 years with a project? I consider the Merger and Acquisition Fee to be unlawful. Let’s be frank about why RIPE has it: there are people who have 20 LIRs across 20 companies (through which they acquired IPv4 in the past before it ran out—congratulations), they pay 20× the annual fee, and there is concern that they might merge those companies into one. RIPE, however, ignores the basic legal principles of mergers, whose core is universal succession of the dissolving companies to the successor entity. This is the same type of succession as, for example, inheritance, where a son inherits his father’s house. It is not a “sale” or a “transfer”—the new entity steps into the relationships of the original one as if it had never ceased to exist. A procedure whereby, after such a “transfer,” resources cannot be transferred for several years, or where a fee is charged for a change in records (when that transfer occurred by operation of law under the legislation of any EU Member State—and I assume the same applies outside the EU), is contrary to the law. Moreover, as a consequence of a merger (where, for example, an entity that currently holds resources ceases to exist), no other situation can legally arise than that everything passes to the successor entity. There cannot be a “non-transfer” because someone failed to pay a fee. That simply cannot happen legally. *** In conclusion, I disagree with the discount for educational institutions. RIPE members also include various organizations close to, for example, non-profits, start-up entrepreneurs, etc., who must pay the full fees. Educational institutions are generously funded by the state, have many employees, often enormous budgets, and the fees discussed here are, compared to small companies with just a few people, entirely negligible for them. *** Unfortunately (or fortunately), I will not change RIPE (or the RIR system as a whole), nor the overall policy of how these organizations operate. I do hope, however, that my thoughts will contribute to reflection among other members. Michal Krajcirovic