Interpretación de la propuesta por el staff de LACNIC
Autor
Jordi Palet
Aplicación de la propuesta
Esta propuesta establece cambios en el Manual de Políticas.
Modificación del texto actual
La propuesta hace una modificación al punto “1.2. Principios para una buena administración/custodia”
Comentarios del Staff
1) Reiteramos nuestro comentario 2 del análisis de impacto de la versión anterior. “Asignar recursos a personas físicas que no estén registradas ante un ente tributario, conlleva mayores riesgos a la hora de cumplir la normativa legal de control (compliance). Esto incluye posibles casos de falsificación de documentos y dificultades en la validación de la identidad. La existencia de una figura legal, permite consultar bases de datos oficiales para responder ante algún conflicto.”
2) Particularmente, actuar con personas físicas no registradas, requiere una debida diligencia intensificada para dar cumplimiento a la normativa vigente de “prevención de lavado de activos, lucha contra el financiamiento del terrorismo y la proliferación de armas de destrucción masiva” (PLAFT).
Recomendaciones del Staff
1) No tenemos recomendaciones sobre esta versión de la propuesta.
Impacto en el sistema de registro y/u otros sistemas
La propuesta potencialmente tiene un alto impacto operativo, institucional y legal.
The LACNIC policies in force only consider the distribution of resources to "Organizations."
This proposal seeks to modify the policy to allow, as in other regions, the distribution of resources to natural persons, businesses or individuals who wish to be directly connected to the Internet and pay for BGP services.
Rationale (Describe the problem you intend to solve)Possibly due to the clear shortage of IPv4 addresses—and at the time even a shortage of AS numbers—the wording chosen for the policy explicitly allows resources to be distributed exclusively to "organizations."
However, as we increasingly rely on resilient Internet connectivity and IPv6-only, it is reasonable to expect that any individual (natural person)—whether acting in a personal capacity (household/family) or engaged in economic or business activities—may wish to avoid depending on third-party addresses and have the right to obtain their own Internet resources, thus allowing the use of IPv6 with multihoming.
Although an avalanche of resource requests is not expected (this has not happened in the other regions), this might change in the future, so we must be prepared. Excluding natural persons, whether for personal use or for conducting economic activities (which the law permits without requiring formal incorporation), while allowing only organizations to obtain essential resources for connecting directly to the Internet would undoubtedly be considered discriminatory under the laws of democratic countries.
It would be paradoxical if, for example, national legislation allows an individual to launch a data center, yet they cannot do so because LACNIC's policies, unlike those of other RIRs, do not allow them to receive resources as independent entrepreneurs. This situation not only generates discrimination against the region's citizens but also a loss of competitiveness compared to the rest of the world.
Current text1.2. Principles for Proper Administration and Stewardship
The fundamental principle is to distribute unique Internet numbering resources according to the technical and operational needs of the networks currently using, or that will use, these numbering resources, allowing the sustainable growth of the Internet.
The numbering resources under the stewardship of LACNIC must be distributed among organizations legally constituted within its service region [SERVICE REGION] and mainly serving networks and services operating in this region. External clients connected directly to main infrastructure located in the region are allowed. Exceptions may be granted to DNS root server operators (RSOs) from outside the service region for the purpose of operating global anycast DNS root service.
* “Mainly” is understood to mean more than 50%.
Anycast services that use numbering resources outside said region are acceptable as long as they are provided by an organization legally established within the service region [SERVICE REGION] and at least one copy of the service is hosted on local infrastructure.
Upon obtaining any type of resources from LACNIC or from the corresponding NIR, any legacy resources held by the recipient will no longer be considered legacy resources.
New text1.2. Principles for Proper Administration and Stewardship
The fundamental principle is to distribute unique Internet numbering resources according to the technical and operational needs of the networks currently using, or that will use, these numbering resources, allowing the sustainable growth of the Internet.
The numbering resources under the stewardship of LACNIC must be distributed among organizations legally constituted within its service region [COBERTURA] and mainly serving networks and services operating in this region. External clients connected directly to main infrastructure located in the region are allowed. Exceptions may be granted to DNS root server operators (RSOs) from outside the service region for the purpose of operating global anycast DNS root service.
* “Mainly” is understood to mean more than 50%.
Anycast services that use numbering resources outside said region are acceptable as long as they are provided by an organization legally established within the service region [SERVICE REGION] and at least one copy of the service is hosted on local infrastructure.
Distributions may be made to natural persons, provided they are legal residents of the LACNIC service region and that the resources will be used exclusively within the region.
Upon obtaining any type of resources from LACNIC or from the corresponding NIR, any legacy resources held by the recipient will no longer be considered legacy resources.
Additional informationTo the best of our knowledge, this restriction does not exist in the other RIRs. On the contrary, there are documented cases of natural persons who, even with no economic activity, have obtained resources from their respective RIRs.
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Presented at:LACNIC 43 (07/05/2025)
LACNIC policies currently in force only contemplate the distribution of resources to "Organizations", even though LACNIC has confirmed it interprets sole proprietors (in Spanish, monotributistas) and similar entities (individuals with economic activity) as "organizations," and therefore eligible to receive distributions or assignments.
This proposal seeks to modify the policy to allow, as in other regions, the distribution of resources to natural persons WITHOUT economic activity, for example, researchers or citizens who wish to connect directly to the Internet and pay for BGP services.
Note: Clarifying the current text of the policy manual so that there is no doubt about its literal meaning regarding sole proprietors/similar entities is the object of another proposal. This proposal refers only to natural persons WITHOUT economic activity.
Rationale (Describe the problem you intend to solve)Possibly due to the clear shortage of IPv4 addresses—and at the time even a shortage of AS numbers—the wording chosen for the policy explicitly allows resources to be distributed exclusively to "organizations."
However, as we increasingly rely on resilient Internet connectivity and IPv6-only operation, it is reasonable to expect that any individual (natural person without economic activity),
acting in a personal capacity (household/family) may wish to avoid depending on third-party addresses and have the right to obtain their own Internet resources, thus allowing the use of IPv6 with multihoming.
Although an avalanche of resource requests is not expected (this has not happened in the other regions), this might change in the future, so we should be prepared. Excluding natural persons, whether for personal use or for conducting economic activities (which the law permits without requiring formal incorporation), while allowing only organizations to obtain essential resources for connecting directly to the Internet would undoubtedly be considered discriminatory under the laws of democratic countries. It should be noted that, since the inception of the Internet, addresses have been allocated to individuals, and this practice has not changed.
This policy would equalize the status of researchers and citizens of the LACNIC region with those in three other regions (APNIC, AFRINIC, and RIPE), thereby enhancing the region's competitiveness. The same occurs in the case of ARIN, although in this case it depends on the specific state/country.
Current text1.2. Principles for Proper Administration and Stewardship
No such text exists.
1.2. Principles for Proper Administration and Stewardship
(Add this at the end of the section)
Distributions or assignments will be made to natural persons without economic activity, provided they are legal residents of the LACNIC service region and that the resources will be used mostly within this region.
Note: Distributions/allocations made by LACNIC are made to a specific holder and under the conditions that were originally justified, and are therefore subject to continued compliance with the policies in force policies. A change of holder may be considered a transfer, or may require re-evaluating the justification and, if applicable, the recovery of the resources.
Additional informationAs far as we know, this restriction does not exist in the other RIRs. On the contrary, in every region individuals without economic activity have obtained resources from their respective RIR.
In the case of ARIN, resources are provided to individuals without economic activity depending on whether their state or country's legislation allows them to obtain a "registration number" for identification purposes with ARIN. In some cases, this registration number does not require any additional processing.
Timetable-
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Presented at:-