Hi Clara, all,

In my opinion, it will make sense that if you received the resources as legacy 
and you want to keep that status, you only get the basic set of services, just 
to keep the registry updated, unless you are a member and pay for the “total 
set of services”.

I know this is a different point but I think it is related and should be 
mention as well. APNIC resolved that and also a policy proposal that reached 
consensus allows those recourses to be reclaimed if there is no response from 
the holder.

The ability to transfer should not be part of the “basic” set of services, so 
clearly, if a legacy holder want to transfer, need to lose the legacy status 
for those resources, and following the same rationale, members that have signed 
a contract (for example they need IPv6 or ASN), they should have lost the 
legacy status of other resources.

Regards,
Jordi

@jordipalet


> El 27 oct 2025, a las 17:12, Wade, Clara via address-policy-wg 
> <[email protected]> escribió:
> 
> Hello everyone,
>  
> Following the suggestion of the RIPE NCC, we are seeking early feedback on an 
> upcoming policy proposal we currently have in draft status.
>  
> As mentioned last week after the Registration Services update from Marco at 
> the AP-WG session - Peter Hessler and I, members of the now concluded 
> Charging Scheme Task Force, are drafting a policy proposal to clarify the 
> non-transferability of legacy status to address the issues of increasing 
> overhead for the RIPE NCC, increasing market speculation around a scarce 
> resource and its impact on the adoption of best practices like RPKI. Our 
> proposal will modify these existing policies:
>  
> “RIPE Resource Transfer Policies” (RIPE-807) with additional clarifications 
> in the Transfer Restrictions section and the Inter-RIR policy section. 
> M&A/org restructuring transfers will be explicitly excluded.
> “RIPE NCC Services to Legacy Internet Resource Holders” (RIPE-639) with 
> modifications to remove the language implying new holders can keep legacy 
> status after transfer.
>  
> For background, legacy status was meant to indicate when an Internet resource 
> had been directly assigned to the holder by IANA, before the RIRs were 
> established. As such, ARIN, LACNIC and AFRINIC policies dictate that IPv4 
> legacy resources will no longer be regarded as legacy resources after a 
> policy transfer takes place (excluding M&A transfers). RIPE is the only RIR 
> that currently allows the recipient of a legacy transfer the ability to 
> inherit the legacy status that was assigned to the original holder by IANA. 
> This is currently being used as a loophole by certain actors to opt out of 
> having a contractual relationship with the RIPE NCC in order to circumvent:
> 
> RIPE registration services fees.
> The 24-month transfer lock that was introduced by this working group to 
> prevent flipping of scarce resources.
> Needs-based inter-RIR transfer policy utilization requirements in the case of 
> transfers from another RIR to a recipient of a legacy resource transfer in 
> the RIPE region.
> 
> Following the publication of the Report of the RIPE NCC Charging Scheme Task 
> Force, the membership learned that the RIPE NCC currently needs to dedicate a 
> 0.5FTE to process legacy transfers. There are currently around 2,400 legacy 
> resources held by 1,600 holders with no contractual relationship with the 
> RIPE NCC (neither direct nor via a sponsor). That is around 40M IPs total or 
> 5% of RIPE IPv4 space. In the last four years, NCC staff have processed 
> between 370-280 legacy transfers per year, of which roughly a third do not 
> involve a party with a contractual relationship with the NCC. Legacy 
> transfers are more labor-intensive than other transfer types because the due 
> diligence process requires the Registration Services team to manually source 
> and verify pertaining documentation without the benefits of the automated 
> processes for standard allocations. Legacy transfers take an average seven 
> working hours to process when neither party has a contractual relationship 
> with the NCC (around a third of legacy transfers), and six working hours to 
> process when the parties have a contractual relationship with the NCC. If 
> resources lost their legacy status after a transfer, these would then become 
> standard allocations and staff could leverage enhanced compliance checks and 
> automated processes to facilitate any future updates/transfers. These just 
> take 1-3 working hours to process instead. Given that the task force was 
> deemed out of scope for a policy change to address this gap, this is being 
> brought to the attention of the Address Policy Working Group for action.
>  
>  
> If there are any concerns, questions or considerations you would like to 
> bring up before we submit this proposal for discussion in the next week or 
> two, we would really appreciate hearing from you so we can address these 
> and/or incorporate them.
>  
> Thanks in advance,
> Clara Wade
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