The following Draft Policy has been revised:
 
*Draft Policy ARIN-2025-1: Clarify ISP and LIR definitions and references to 
address ambiguity in NRPM text
 
Revised text is below and can be found at:
 
https://www.arin.net/participate/policy/drafts/2025_1/
 
You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate 
the discussion to assess the conformance of this Draft Policy with ARIN's 
Principles of Internet number resource policy as stated in the Policy 
Development Process (PDP). Specifically, these principles are:
 
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
 
The PDP can be found at:
 
https://www.arin.net/participate/policy/pdp/
 
Draft Policies and Proposals under discussion can be found at:
 
https://www.arin.net/participate/policy/drafts/
 
 
Regards,
 
Eddie Diego
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy 2025-1: Clarify ISP and LIR definitions and references to address 
ambiguity in NRPM text

Problem Statement:

Section 2.4 of the NRPM defines an LIR but does not explicitly define an ISP. 
An ISP is defined in the context of an LIR, but the explicit definition is 
otherwise assumed.

Through implication and in common business practice, all ISPs are LIRs, but not 
all LIRs are ISPs.

This proposal adds clarity by creating an explicit definition for ISP, removing 
an ambiguous word and clarification on usage for the term LIR, removing an 
ambiguous terminology statement in Section 6.5.1a, and changing terms in 
Section 6.5 to explicitly state it applies to “LIR/ISP,” thus fulfilling the 
original intent of 6.5.1a, in all appropriate locations.

Policy Statement:

Add Internet Service Provider definition:

Remove the word “primarily” from the definition of LIR and add usage 
clarification:

FROM: 2.4. Local Internet Registry (LIR)

A Local Internet Registry (LIR) is primarily an IR that assigns IP addresses to 
the users of the network services that it provides. LIRs are generally Internet 
Service Providers (ISPs) whose customers are primarily end users and possibly 
other ISPs.

TO: 2.4. Local Internet Registry (LIR)

A Local Internet Registry (LIR) is an IR that assigns IP addresses to the users 
of the network services that it provides. LIRs are generally Internet Service 
Providers (ISPs) whose customers are primarily end users and possibly other 
ISPs. 

Add definition for ISP:

2.18 Internet Service Provider

An Internet Service Provider (ISP) is a type of LIR organization that provides 
Internet services to other organizations, its customers, and\or individuals 
other than its employees. Internet services include, but are not limited to, 
connectivity services, web services, colocation, dedicated servers, virtual 
private servers, and virtual private networks.

Replace Section 6.5.1a

Original Text: “The terms ISP and LIR are used interchangeably in this document 
and any use of either term shall be construed to include both meanings.”

New Text: “[Retired]”

Change all references in section 6.5 to use LIR/ISP, where appropriate:

[Editing note: For the purposes of clarity in plaintext communication mediums, 
any addition of LIR or ISP to the text is denoted with the underscore character 
before and after the insertion. The underscore character is not considered a 
part of the final text.]

Amend Section 6.5.2 to add ISP and LIR in 15 locations

6.5.2. Initial Allocation to LIRs_/ISPs_

6.5.2.1. Size

1. All allocations shall be made on nibble boundaries.

2. In no case shall an LIR_/ISP_ receive smaller than a /32 unless they 
specifically request a /36 or /40. In order to be eligible for a /40, an 
_LIR/_ISP must meet the following requirements:

* Hold IPv4 direct allocations totaling a /24 or less (to include zero) 
* Hold IPv4 reassignments/reallocations totaling a /22 or less (to include 
zero) 

In no case shall an _LIR/_ISP receive more than a /16 initial allocation.

3. The maximum allowable allocation shall be the smallest nibble-boundary 
aligned block that can provide an equally sized nibble-boundary aligned block 
to each of the requesters serving sites large enough to satisfy the needs of 
the requesters largest single serving site using no more than 75% of the 
available addresses.

This calculation can be summarized as /N where N = P-(X+Y) and P is the 
organization’s Provider Allocation Unit X is a multiple of 4 greater than 
4/3serving sites and Y is a multiple of 4 greater than 4/3end sites served by 
largest serving site.

4. For purposes of the calculation in (c), an end site which can justify more 
than a /48 under the end-user assignment criteria in 6.5.8 shall count as the 
appropriate number of /48s that would be assigned under that policy.

5. For purposes of the calculation in (c), an LIR_/ISP_ which has subordinate 
LIRs_/ISPs_ shall make such reallocations according to the same policies and 
criteria as ARIN. In such a case, the prefixes necessary for such a 
reallocation should be treated as fully utilized in determining the block 
sizing for the parent LIR_/ISP_. LIRs_/ISPs_ which do not receive resources 
directly from ARIN will not be able to make such reallocations to subordinate 
LIRs_/ISPs_ and subordinate LIRs_/ISPs_ which need more than a /32 shall apply 
directly to ARIN.

6. An LIR_/ISP_ is not required to design or deploy their network according to 
this structure. It is strictly a mechanism to determine the largest IP address 
block to which the LIR_/ISP_ is entitled.

7. An LIR_/ISP_ that requests a smaller /36 or /40 allocation is entitled to 
expand the allocation to any nibble aligned size up to /32 at any time without 
renumbering or additional justification. /40 allocations shall be automatically 
upgraded to /36 if at any time said LIR_/ISP_’s IPv4 direct allocations exceed 
a /24. Expansions up to and including a /32 are not considered subsequent 
allocations, however any expansions beyond /32 are considered subsequent 
allocations and must conform to section 6.5.3. Partial returns of any IPv6 
allocation that results in less than a /36 of holding are not permitted 
regardless of the _LIR/_ISP’s current or former IPv4 address holdings.

Amend Section 6.5.2.2 to add LIR in 2 locations:

6.5.2.2. Qualifications

An organization qualifies for an allocation under this policy if they meet any 
of the following criteria:

1. Have a previously justified IPv4 _LIR/_ISP allocation from ARIN or one of 
its predecessor registries or can qualify for an IPv4 _LIR/_ISP allocation 
under current criteria.

2. Are currently multihomed for IPv6 or will immediately become multihomed for 
IPv6 using a valid assigned global AS number. In either case, they will be 
making reassignments or reallocations from allocation(s) under this policy to 
other organizations.

3. Provide ARIN a reasonable technical justification indicating why an 
allocation is necessary. Justification must include the intended purposes for 
the allocation and describe the network infrastructure the allocation will be 
used to support. Justification must also include a plan detailing anticipated 
reassignments and reallocations to other organizations or customers for one, 
two and five year periods, with a minimum of 50 assignments within 5 years.

Amend Section 6.5.3 to add ISP in 4 locations:

6.5.3. Subsequent Allocations to LIRs_/ISPs_

1. Where possible ARIN will make subsequent allocations by expanding the 
existing allocation.

2. An LIR_/ISP_ qualifies for a subsequent allocation if they meet any of the 
following criteria:

* Shows utilization of 75% or more of their total address space 
* Shows utilization of more than 90% of any serving site 
* Has allocated more than 90% of their total address space to serving sites, 
with the block size allocated to each serving site being justified based on the 
criteria specified in section 6.5.2 

3. If ARIN can not expand one or more existing allocations, ARIN shall make a 
new allocation based on the initial allocation criteria above. The LIR_/ISP_ is 
encouraged, but not required to renumber into the new allocation over time and 
return any allocations no longer in use.

4. If an LIR_/ISP_ has already reached a /12 or more, ARIN will allocate a 
single additional /12 rather than continue expanding nibble boundaries.

Amend Section 6.5.4.1 to add ISP in 1 location:

6.5.4.1. Reassignment to Operator’s Infrastructure

An LIR_/ISP_ may reassign up to a /48 per PoP as well as up to an additional 
/48 globally for its own infrastructure.

Amend Section 6.5.5 to add LIR in 1 location:

6.5.5. Registration

_LIRs/_ISPs are required to demonstrate efficient use of IP address space 
allocations by providing appropriate documentation, including but not limited 
to reassignment and reallocation histories, showing their efficient use.

Amend Section 6.5.5.4 to add LIR in 1 location:

6.5.5.4. Registration Requested by Recipient

If the downstream recipient of a static assignment of /64 or more addresses 
requests publishing of that assignment in ARIN’s registration database, the 
_LIR/_ISP shall register that assignment as described in section 6.5.5.1.

Amend Section 6.5.7 to add ISP in 1 location:

6.5.7. Existing IPv6 Address Space Holders

LIRs_/ISPs_ which received an allocation under previous policies which is 
smaller than what they are entitled to under this policy may receive a new 
initial allocation under this policy. If possible, ARIN will expand their 
existing allocation.

Amend Section 6.5.9 to add LIR and ISP in 2 locations:

6.5.9. Community Network Allocations

While community networks would normally be considered to be LIR/ISP type 
organizations under existing ARIN criteria, they tend to operate on much 
tighter budgets and often depend on volunteer labor. As a result, they tend to 
be much smaller and more communal in their organization rather than 
provider/customer relationships of commercial ISPs. This section seeks to 
provide a policy that is more friendly to those environments by allowing 
community network to receive a smaller allocation than other LIRs or commercial 
ISPs. Community networks may also qualify under section 6.5.2 as a regular 
LIR/ISP.

Amend Section 6.5.9.2 to add ISP in 1 location:

6.5.9.2. Allocation Size

Community networks are eligible only to receive an allocation of /40 of IPv6 
resources under this section. Community networks that wish to receive a larger 
initial allocation or any subsequent allocations must qualify as a regular 
LIR_/ISP_, see sections 6.5.2 or 6.5.3 respectively.

Amend Section 6.5.9.3 to add ISP in 1 location:

6.5.9.3. Reassignments by Community Networks

Similar to other LIRs_/ISPs_, Community networks shall make reassignments to 
end-users in accordance with applicable policies, in particular, but not 
limited to sections 6.5.4 and 6.5.5. However, they shall not reallocate 
resources under this section.

Timetable for Implementation: Immediate.


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