Dear SIG Members,
Please find below the Secretariat impact assesment for prop-165-v003 :
Provision of IPv4 Address Space to IPv6-only Networks for Transitional Purpose
Dave Phelan
Policy Manager and Senior Network Analyst
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1. APNIC’s Understanding of the Proposed Policy
APNIC understands this proposal as allowing members that hold an IPv6
allocation to request one IPv4 /24 delegation for IPv6-only network transition
purposes.
The proposal is expected to affect a limited number of members. APNIC
Secretariat notes that, as of 30 June 2026, 1.2% of APNIC members held IPv6 but
not IPv4.
The proposal states that the IPv4 block must not be permanently reassigned to
another organisation.
2. Impact of Proposed Policy on Registry and Addressing System
Registry systems would need to identify IPv4 /24 delegations made under this
policy, link them to the member’s IPv6 allocation, and apply the specific
policy conditions.
Additional clarification may be needed on whether these blocks can be
temporarily reassigned or sub-assigned, given the proposal only prohibits
permanent reassignment
The following question from the previous assessment still remain outstanding
How should the Secretariat monitor if their IPv4 is being used to support their
IPv6-only network and not being used for some other purpose?
3. Impact of Proposed Policy on APNIC Operation/Services
APNIC would need to create an assessment process for requests under this policy
and provide guidance on how to conduct periodic reviews.
The Secretariat is requesting guidance on how they should periodically check
whether the IPv4 resources remain necessary for transitional purposes.
The sunset provision requires further clarification before implementation. The
proposal includes three separate triggers: projected exhaustion of the Final /8
pool within six months, a community-determined minimum threshold, and a
determination by the APNIC Executive Council that continued operation would
materially threaten equitable access to remaining IPv4 resources.
APNIC would need a clear operational method for applying these triggers,
including how exhaustion projections are calculated, how often they are
reviewed, what data is used, and how the result is published. The proposal does
not currently define the community threshold, which would need to be specified
before that trigger could be implemented.
The EC-based trigger would also require clarification, including the criteria
for making such a determination, whether the suspension of new delegations is
temporary or permanent, and how this interacts with the normal policy process.
4. Legal Impact of Policy
We note that the phrase ‘permanently re-assigned’ implies some form of
reassignment may be allowed, provided it is not permanent. It would be helpful
to understand if there is a deliberate intention behind this to guide our
interpretation and the development of corresponding procedures.
The Proposed Policy will require a number of amendments to APNIC-127, however
the specific implementation of such changes has not been made clear by the
Authors. This uncertainty may create a number of enforcement and assessment
challenges depending on its implementation, which can be considered further
following clarification of the Secretariat’s questions in other parts of this
impact assessment.
5. Implementation
Implementation would require clarification of the sunset mechanism, including
the calculation method for projected exhaustion, the value and form of the
community-determined threshold, and the process for any EC determination. APNIC
would also need to define how applications in progress are handled if a sunset
condition is triggered.Until such point as these clarifications are made, we
are unable to make a determination on implementation process and time frames.
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