Dear AP-WG, 

While researching for my recent MENOG25 presentation, I noticed a transparency 
gap around IPv4 leasing — where LIRs delegate a block of address space to third 
parties who then operate it. A reportedly growing practice in our region and 
globally, driven by legitimate organisational needs for temporary IPv4 
capacity. Yet there are no clear common guidelines for how LIRs should document 
who actually operates leased space, resulting in inconsistent registration 
practices. A sample taken of 50 leased prefixes showed multiple status 
attributes in use, only 26% with abuse contacts, and over half with no 
identification of the actual operator of the address space (or the ‘lessee’).

- The Problem -

Back in 2021, the RIPE Database Requirements Task Force established that 
registration data should be accurate to "facilitate contact with and 
identification of the organisation holding the assignment" (RIPE-767). The Task 
Force also strongly recommended that where a resource holder delegates 
resources to another entity, this should be documented.

Existing registration mechanisms can technically accommodate leasing — LIRs can 
create assignments or sub-allocations. But without specific guidance, these 
registrations frequently fail to identify the actual operator or provide 
functional abuse contacts. Research from the University of Twente estimated 
6.1% of routed prefixes were leased in February 2025, and found leased prefixes 
then were 2.89× more likely to be blocklisted — a disparity that warrants 
examination regardless of root cause.

In practice, this means:

1. Rather than the actual operator of the IP block, abuse complaints frequently 
reach the LIR/lessor who may have no operational control
2. WHOIS often does not identify ‘who is’ actually operating the address space

- The Question -

Does the WG believe this transparency gap warrants discussion?

With ongoing IPv4 recycling, leasing may well become an increasingly common 
practice. Establishing clear registration expectations now seems preferable to 
addressing this retroactively.

- Possible Approaches -

If the WG sees value in addressing this, potential mechanisms could range from:

* A policy principle: where a third party operates leased address space, they 
should be identifiable
* Guidance on what information LIRs should document for consistency, including 
functional abuse contacts and lease duration
* A new status attribute (e.g., "LEASED PA") to explicitly reflect this 
distinct type of delegation of public IP space from an LIR to a third party

- Clarification -

'Standard' assignments — where the LIR provides services and retains 
operational involvement — are not in scope. This applies only where a third 
party operates the space without direct involvement from the LIR. No commercial 
terms or pricing need be disclosed — only who to contact and who is operating 
the space.

- Discussion Points -

* Is the transparency gap problematic enough to warrant action?
* What information would be operationally useful to capture? 
* What implementation challenges or unintended consequences should we consider?

I have already consulted with stakeholders who see value in this direction, but 
I'm keen to hear broader perspectives from the WG.


Best regards,
James Kennedy

https://www.kipa.global


References:
University of Twente — "From Scarcity to Opportunity: Examining Abuse of the 
IPv4 Leasing Market" (2025): 
https://ris.utwente.nl/ws/portalfiles/portal/497142547/tma2025_paper18.pdf
RIPE Database Requirements Task Force Report (RIPE-767): 
https://www.ripe.net/publications/docs/ripe-767




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