Kenny Huang recently published a smart, detailed piece on CircleID, Resilience vs. Sovereignty: Implementation Challenges of RIR Emergency Operations Under the ICP-2 Framework, about what happens when the organizations that manage Internet number resources—the RIRs—face an emergency. Sanctions. War. A host country collapsing. He walks through the technical and legal mess that follows. It’s good work. You should read it.

Kenny is designing the system for you. I’m telling you how to survive it until he’s done.

His recommendations, harmonize policies, build transnational legal frameworks, and strengthen the NRO, are exactly what the system needs. Long term. But the 2026 application window is open now. You are signing contracts now. Your registry provider’s legal home is a fact, not a future hope.

This article isn’t about fixing the RIRs. It’s about making sure you don’t get stranded while they figure it out.

What Huang’s Analysis Actually Means for You

Huang lays out three problems that should keep you up at night.

1. Policy fights. RIRs have different rules. In a crisis, nobody agrees whose rules win.
2. Jurisdictional limbo. If an RIR has to move because of sanctions or war, who says the new entity is legit? International law is silent.
3. Orphaned contracts. You signed with RIR A. RIR A no longer exists. Who holds your contract now? Who enforces it?

These are not theoretical. They are real, foreseeable risks for anyone whose infrastructure lives in a contested part of the world. And I promise you, your due diligence checklist does not have a line item that says: “What if our registry’s legal home disappears?”

A New Kind of Due Diligence: The Infrastructure Sovereignty Audit

If you’re a serious applicant, your checklist just got longer. Technical backups and money in the bank are table stakes now. Infrastructure sovereignty is the new test.

Here are the questions you need to ask your registry provider—not their tech team, their lawyers and strategists.

1. Where are you legally based? What’s your plan if you have to move? If your RIR relocates because of sanctions or conflict, how do my rights survive? Who signs the new contract? What’s the trigger? What’s the timeline?
2. What happens if RIRs disagree in an emergency? My string is delegated under your RIR’s rules. If emergency ops shift to another RIR with different rules, which ones apply to me? Who decides? Who do I appeal to?
3. Have you tested your backup plan against a political collapse, not just a technical one? A server farm going dark is one thing. A country dissolving your legal entity is another. Show me the playbook for the second one.
4. What does your contract say about “the RIR stops existing”? Standard force majeure covers earthquakes and floods. It does not cover “our legal home vanished under international law.” Is that gap filled? If not, why not?

These aren’t academic. They are the direct, predictable consequence of the fragmentation Huang lays out. If you’re not asking them, you’re not ready.

What .Africa Taught Me About Accountability - and Why It Matters Here

In the .Africa case, we won an Independent Review Process against ICANN. The IRP panel ruled that the ICANN Board violated its own bylaws. That win is public record.

But here’s what I learned the hard way: the IRP has a very short leash. It only looks at what the Board did. It cannot touch staff conduct, contracted panels, or the CEO. Those parts of the system have no remedy. No policy. No second chance. The door just doesn’t exist.

That means the IRP was never designed to fix certain kinds of problems. It exists for Board decisions. It does not exist for a registry that vanishes under foreign sanctions law, or an RIR whose emergency successor changes the rules on you, or a fight that lives in private international law—not ICANN bylaws—with no court, no judge, no agreed rules.

Huang calls this a “grey area.” I call it a black hole.

I found that out when we tried to take the next step. The 2026 applicant who picks a registry in the wrong jurisdiction—and watches that jurisdiction collapse—will hear what I heard: “This isn’t ICANN’s problem. Go find a court.”

Which court? Under what law? Against whom, when the company you signed with no longer exists?

That’s not justice. That’s a game with no board, no pieces, and no rules. And you lose just by showing up.

The Prepared Applicant, 2026 Edition

Back in January, I wrote that the unprepared applicant is the one who hasn’t mapped their governance battlefield. You can read that piece here: https://circleid.com/posts/the-unprepared-gtld-applicant-of-2026

That battlefield just moved.

It’s not just about GAC objections or string similarity algorithms anymore. It’s about the ground your registry stands on. That ground isn’t technical. It’s legal. It’s jurisdictional. It’s sovereign. And it’s cracking.

The 2026 applicant who picks a contested registry has no roadmap. No precedent. No forum.

I know. I’ve stood in that empty room.

So here’s the question you need to answer before you sign anything: Is your infrastructure sovereign—or is it contested? And if it’s contested, what’s your plan?