Hi Denis,

Thanks for your message and apologies for the delayed response.

The recent updates to the Terms and Conditions were introduced to
facilitate the implementation of the new Digital Operational Resilience Act
(DORA) by those members that fall within the scope of this Act. Such
members include insurance companies, financial institutions, etc. By
introducing the points you mentioned, we aim to facilitate, as much as
possible, our members’ ability to meet their obligations.

By setting out these general provisions in the clauses, we wanted to make
clear, among others what possibilities exist, for example, in terms of the
audits, security checks, and incident reporting, and to clearly state in
writing the options our members have in these areas in relation to the use
of the RIPE Database.

Regarding your questions about clauses 5.6, 5.7, who “the Registrant” and
“the Maintainer” refer to, whether they can report any identified incidents
or incidents relating to their resources, what types of incidents are meant
and whether Users can also report incidents, please see below:



For the phrasing, much of the text follows standard legal language (when we
use “the” before “Registrant” or “Maintainer” this means they must be read
as the terms defined in Article 1 of the T&Cs). As the amendments were part
of our efforts to facilitate members that fall under the scope of DORA, we
only indicated the incident reporting ability with regards to  Registrants
and Maintainers. They may report any incident they identify when using the
RIPE Database. This does not restrict any user to also report outages or
incidents to our Technical Emergency Hotline and security issues to our
security team, following our RIPE NCC Technical Emergency Hotline
<https://www.ripe.net/about-us/support/contact/technical-emergency-hotline/>
process.

In relation to your questions about 5.9 and audit reports, the scope of a
security check or audit depends on the matter at hand and might differ on a
case-to-case basis. An available report of such a check or audit may be
provided to a Registrant or Maintainer subject to a non-disclosure
agreement. Please refer above on how to read the terms “Registrant” or
“Maintainer”.

Although the RIPE Database is publicly accessible, certain information
within it is not. Therefore, information about protection, integrity and
confidentiality of the data remains relevant for the Database in this
context.

Regarding your point about 2023-04 ‘Add AGGREGATED -BY-LIR status for IPv4
PA assignments’ to our understanding, this proposal did not make IPv4
assignments optional but introduced the option to group assignments in a
single registration when the assignments share the same purpose and contact
details. Even for such grouped assignments, authorised parties will still
be able to find the contact details of their responsible party and contact
them.

Lastly, thank you for pointing out the missing text in article 2.6, we’ve
corrected the error on the website. We have also separated the two
definitions of RPSL and Internet Number Registry that Piotr noticed.

Kind regards,

Maria Stafyla
Legal Counsel Specialist
RIPE NCC

> On Wed, Nov 12, 2025 at 11:04:00PM +0100, Piotr Strzyzewski wrote:
>
> Dear Denis, All,
>
> "2.6. A Maintainer may only Update the RIPE Database with these types of
> data:"
> This line ends with a ':'. That suggests there should be a list following
> it. There is no list. If you change ':' to '.' then the sentence makes no
> sense.
>
>
> The list comes right after that sentence. From what I can see, it's just
> missing bullet points. I'll pass this information on to the relevant
> team.
>
> Now let's look at "Article 1 - Definitions"
> "Internet number resources - globally unique address space (IPv4 and IPv6)
> and Autonomous System Numbers (ASNs) issued by any Internet Number
> Registry."
> Note it says 'any' Internet Number Registry. An LIR is a Local 'Internet
> (Number) Registry'. So 'Internet number resources' covers address space
> issued by an LIR. These are assignments.
>
>
> For some unknown reason, the definition of Internet Number Registry
> (INR) has been linked to and placed at the end of the RPSL definition.
> That definition uses the word "allocates". I'll pass this information on
> to the relevant team.
>
>
> Let me report back to you that, thanks to Marita's prompt help, these
> two formatting issues have already been fixed. I hope that helps.
>
> Best,
> Piotr
>
> --
> Piotr Strzyżewski
>
>
>
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