eco Comments on European Commission Study on DNS Abuse

The Domain Name System (DNS) is a core function of the Internet because for people it converts readable domain names into IP addresses. The eco Association has been working for many years on a range of activities to protect this “telephone book of the Internet” from manipulation and abuse and to guarantee its stability and reliability. For more than 25 years, eco has been intrinsically motivated to make sure that abuse and illegal content on the Internet are combated and that crimes are prosecuted. In recent times, the topDNS initiative has been a key factor which has enabled eco Association to apply a special weight to meeting this goal. The EU Commission has also dealt with the topic in detail and published a “Study on Domain Name System (DNS) Abuse” on 31 January 2022.

The eco Association welcomes the impetus of the European Commission and the authors to “analyse the scope, impact and magnitude of DNS abuse”. The present “Study on Domain Name System (DNS) Abuse” is one of the most comprehensive works on this topic.

Good insights, but also flaws

“After an intensive analysis undertaken together with the members of the association, we have to conclude that the study and the associated technical annexes are not consistent in all aspects. Also, some of the recommendations cannot be reconciled with applicable law”, says attorney-at-law Thomas Rickert, Director Names & Numbers at the eco Association. The association also takes a critical stance regarding the very broad definition of DNS abuse proposed by the authors. In some instances, it makes it difficult to appreciate the relevant insights of the study, such as the fact that combating DNS abuse cannot be done primarily by registries and registrars of domain names, but that a whole range of intermediaries must work together to solve the problem holistically.

By distinguishing between maliciously registered and compromised domain names, the study has also given a positive momentum to the discussion on DNS abuse, especially in the ICANN community.

Policymakers and the industry need to work more closely together

However, as the study was also prepared with the aim of influencing further political developments in the European Union, the association members call on the European Commission and political decision-makers to read the study with caution and in conjunction with the comments of the eco Association and others. The eco Association and its members are working unabated in an open dialogue between the industry and policymakers to shape a secure Internet with a secure DNS.

Download Comment on the Study on Domain Name System (DNS) Abuse

eco Comments on European Commission Study on DNS Abuse