eco Association presents flexible contract template for registries and registrars—already presented as a best practice at ICANN.

The German implementation law for the NIS2 Directive entered into force on 6 December 2025. For registries, registrars, resellers and providers of privacy and proxy services, Article 28 in particular represents a key challenge. With the progressive implementation in EU Member States, the pressure to act is increasing for all parties involved.

Article 28 requires companies that offer domain name registration services to cooperate. But how can this cooperation be implemented in practice? The foundation is the Registry-Registrar Agreement (RRA) of the Internet Corporation for Assigned Names & Numbers (ICANN).

To efficiently integrate the requirements of the NIS2 Directive into existing contractual relationships, Thomas Rickert, Attorney-at-Law and long-standing Director of Names & Numbers at the eco Association, has developed a template for a supplementary annex to the RRA. This is flexibly adaptable to different business models—regardless of whether a registry uses the “Minimum Data Set” concept of the new ICANN policy or processes additional registration data. In addition to other parameters, it also allows flexible determination of which party is responsible for verifying and validating the registration data.

Successful implementation in practice

The operators of the top-level domains .wien, .koeln, .cologne and .tirol have already successfully supplemented their RRAs based on this template. Ronald Schwärzler, CEO of domainworx Service & Management GmbH, explains: “The template was a valuable tool for us to reach the necessary agreements with our registrars in accordance with Article 28 of the NIS2 Directive—without having to contact each accredited registrar individually. We presented this approach as a best practice to ICANN’s Governmental Advisory Committee (GAC) at the ICANN84 meeting in Dublin and received very positive feedback.”

Contact for further information

Interested companies can request the template from the eco Association: [email protected]

Learn more and register for the webinar explaining this practical solution:
https://www.eco.de/event/nis2-in-the-domain-industry-act-now-a-practical-solution-for-article-28-implementation/