ENS Public Goods Working Group: Funding ICANN Engagement and Policy Advocacy

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Summary

For the next installment of the ENS Public Goods (PG) Working Group Strategic Grants programme, we are allocating a grant of up to $25,000 USDC to support ICANN engagement through the expertise of Emily Murray. This initiative ensures ENS can effectively represent web3 interests within the ICANN community ahead of the next new gTLD program launching in April 2026.

Why This Funding Matters

Web3 domains and decentralized identifiers are increasingly intersecting with the traditional DNS, yet the majority of ICANN stakeholders have limited understanding of these resources. Without timely engagement, key issues such as name collision, security risks, and ethical governance of decentralized resources may be overlooked. This grant allows for:

• Educating ICANN stakeholders on the benefits & challenges of web3 domains to counter misinformation and skepticism around blockchain-based domains

• Educating web3 and blockchain companies about ICANN matters that are relevant to their industry interests, particularly the opportunities and challenges presented by ICANN’s new gTLD program

• Influencing gTLD policy proactively, ensuring fair and safe integration of web3 interests

• Strengthen ENS’s reputation as a positive and ethical force within ICANN, thus paving the way for broader ICANN engagement and effective advocacy by the web3 community

• Provide public goods impact by advancing transparency, advocacy, and responsible participation in Internet governance

Background / Overview

ENS is actively engaging with ICANN ahead of the next new gTLD program launching in April 2026. While ENS has strong internal leadership through Alex Urbelis (General Counsel, ENS Labs), the scale and timing of ICANN engagement require dedicated support to ensure timely submissions of public comments and real-time monitoring of ICANN meetings.

Emily Murray brings extensive ICANN experience since 2009, including:

• Drafting and prosecuting over 200 new gTLD applications during the 2012 round.

• Participating in more than 50 gTLD objection proceedings.

• Providing ongoing updates on ICANN developments, compliance, and policy guidance.

• Training clients and stakeholders on ICANN processes, new gTLD programs, and enforcement strategies.

“Although web3 has existed for over a decade, it is generally not well understood by the vast majority of the ICANN community… The group has a unique opportunity to make the larger ICANN stakeholder community aware of issues, such as name collision, that are not on the radar of most stakeholders. Due to the impending launch of the new gTLD program in April 2026, these concerns are quite time sensitive, and the group’s investment in the grant will optimize opportunities to raise awareness and engage in advocacy within this narrow time frame.” - Emily Murray

Emily’s involvement ensures that ENS can participate effectively in ICANN’s multistakeholder model, raising awareness of web3 considerations and influencing policy design for the benefit of the broader decentralized Internet ecosystem.

Discrete Projects & Ongoing Workstreams

1. ICANN Public Comment Submissions

• Drafting and submitting public comments on gTLD policy proposals

• Ensuring comments reflect both ENS and broader web3 community priorities

• Raising awareness of issues such as name collisions, security risks, and ethical governance

2. Remote Monitoring of ICANN Meetings

• Attendance at ICANN sessions via remote access

• Real-time updates on policy, procedural changes, and stakeholder discussions

• Early identification of potential objections, risks, or implementation hurdles

3. General ICANN Strategy & Compliance Support

• Reporting on key ICANN developments and gTLD program updates

• Advising ENS on compliance, enforcement, and strategic engagement

Invoicing for the work will be divided, as appropriate, between ENS Labs and the ENS DAO Public Goods working group, depending on whether the work primarily supports ENS business priorities or the broader public interests of the web3 community.

PG Working Group funds:

• Public comments addressing industry-wide web3 concerns (name collision risks, security standards)

• Educational materials for ICANN stakeholders about blockchain domains generally

• Meeting coverage focused on new gTLD program impacts on web3 ecosystem

• Reports shared publicly with web3 community

ENS Labs funds:

• Comments defending ENS-specific interests or .eth domain

• Bilateral meetings with ICANN staff about ENS operations

• Compliance matters specific to ENS registry functions

• Strategic advice on ENS competitive positioning

Work Done / In Progress:

• Draft & Advise on ICANN Public Comments – Supported ENS in submitting comments on the 2026 new gTLD Applicant Guidebook (AGB), highlighting technical issues (e.g., name collisions, string similarity) and gaps affecting underrepresented applicants. So far, two rounds of public comments have been submitted on select portions of the (AGB), with a final set of comments submitted on the full draft AGB that was published by ICANN in May 2025. PG benefit: fair, inclusive Internet governance by establishing ENS as an ethical, educational web3 advocate within the broader ICANN community; representation of broader web3 community interests within development of the new gTLD program

• Monitor & Evaluate External Comments – Tracked and analysed relevant gTLD public comments from other stakeholders, including third-party insights affecting Web3 domains. PG benefit: ensures the web3 community’s unique concerns are represented and encourages informed, multi-stakeholder policy development; identifies gaps where web3 interests are not currently being accurately or well-represented to inform future engagement priorities

• ICANN Meeting Support & Remote Coverage – Advised ENS team on in-person strategy during ICANN meetings (Istanbul, Seattle, Prague) while providing remote session coverage and reporting. PG benefit: maximizes knowledge-sharing, supporting transparent and effective advocacy for the decentralized Internet; offers opportunities to share key information on the new gTLD program and the tenor of ICANN discussions on web3 issues with the broader web3 community

• Strategic Planning for 2025 Engagement – Organizing ENS priorities for upcoming ICANN meetings (Dublin), public comment submissions, and final Applicant Guidebook evaluation. PG benefit: timely, proactive participation in Internet governance, raising awareness of web3 issues and supporting ethical, informed policymaking; ensures the broader web3 community remains informed of key developments in the new gTLD program and other issues that may impact their organizations

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Benefits to ENS & the broader Ecosystem

• Influence & Awareness: ENS can help shape gTLD policies and ensure web3 considerations are included in ICANN’s decision-making. From observations of recent ICANN meeting sessions, it is clear that web3 issues are not on the radar of most members of the ICANN community, including those directly involved in developing gTLD policies. For example, at a recent ICANN meeting, when members of the New gTLD Subsequent Procedures Policy Development Process working group (SubPro) were asked if they had considered web3 matters when developing recommendations for the 2026 new gTLD application round, they advised that they were focused on other priorities and not web3. This appears to be due to both a lack of technical knowledge regarding web3 and a perceived lack of importance. Through consistent participation in the ICANN community, ENS can elevate the importance of web3 matters as well as provide ongoing education to close technical knowledge gaps.

• Transparency & Legitimacy: Public comments and engagement show commitment to open governance and ethical practices. ENS has so far submitted public comments during several opportunities to provide feedback on the draft Applicant Guidebook (AGB), the highly detailed 400-page manual that outlines all the policies, procedures, and requirements for the new gTLD application round due to launch in 2026. These have included two rounds of public comments on select sections of the AGB, as well as a recent comment on the complete draft AGB that ICANN published in late May 2025. Going forward, ENS will submit public comments on the string similarity evaluation process, which public comment window is due to open by late August 2025, as this issue ties directly to the web3 community’s concerns regarding name collision. In addition, ENS will evaluate the opportunity to provide public comments on the draft new gTLD Registry Agreement, which public comment window is due to open in September 2025. We will also track and evaluate any other public comment opportunities that arise relating to the new gTLD program. For example, ICANN is due to publish the final AGB in December 2025; it is not known yet if ICANN will be soliciting public comments on this version of the AGB, but if so, ENS will likely want to take the opportunity to provide comments. In addition to submitting public comments, we will be analyzing comments submitted by third parties that relate to issues of importance to the web3 community, such as name collision, string similarity, and geographic names.

• Education & Advocacy: Raises awareness of alternative domains, blockchain resources, and potential risks among ICANN stakeholders. Again, web3 issues are not well-known and are only infrequently discussed. As an organization that already has an excellent reputation in the ICANN community for acting ethically and in the public interest, ENS has a unique opportunity to serve as a trusted, expert voice on behalf of web3 interests. This participation would counter misinformation that may be spread by web3-related organizations that may be looking to act less ethically (for example, focused on their own business priorities instead of the public good) or by individuals who are misinformed about web3 technical matters.

• Network & Collaboration: Facilitates connections with ICANN decision-makers, potential applicants, and technical experts. The ICANN community comprises numerous stakeholder interests. Areas in which ENS can develop and strengthen connections are: the ICANN Board; ICANN staff, particularly those working on the new gTLD program as well as legal/compliance matters; the Generic Names Supporting Organization (GNSO), which creates global domain name system policy; the Governmental Advisory Committee (GAC), which includes representatives from the majority of countries and territories; the Country Code Names Supporting Organization (ccNSO), which coordinates on policy development for country code top-level domains; the Intellectual Property Constituency (IPC), which is focused on brand protection and other rights protection mechanisms for the new gTLD program; and the Registry and Registrar Stakeholder Groups (RySG and RrSG), which advocate for contracted parties within the ICANN community.
  In addition, we plan to build connections within the Security and Stability Advisory Committee (SSAC), a group of technical experts that appears to be the only area of the ICANN community with a high awareness of web3 issues and potential new gTLD program complications such as name collision.

• Time-Sensitive Impact: Maximizes opportunities to influence policy before the 2026 gTLD launch. Barring any new gTLD program delays, there will only be two more public ICANN meetings before the program launch: ICANN84 in Dublin in October 2025; and ICANN85 in Mumbai in March 2026. In addition, as outlined above, there are only a small number of remaining public comment opportunities that have been announced in connection with the new gTLD program. However, through consistent engagement with the various ICANN stakeholder groups detailed above both during and surrounding ICANN meetings, and through submission of public comments at each available opportunity, ENS can optimize the reach of its advocacy on behalf of the web3 community.

• Full reporting of the work and its success in informing and influencing the perception, inclusion and understanding of web3 within the broader Internet ecosystem. An additional goal will be to collate key information about the current state of ICANN and the new gTLD program to share with the broader web3 community, beyond the ENS PG Working Group, thus ensuring that this community has opportunities as desired to consider participation in the new gTLD program or further direct engagement with ICANN advocacy.

Conclusion

Funding this project ensures ENS can represent web3 interests within ICANN, influence the new gTLD program, and provide broad benefits to the decentralized Internet ecosystem at the intersection with the traditional status quo, including sharing information about the new gTLD program and other ICANN activities with other web3 organizations.This work strengthens transparency, promotes ethical governance, and shares knowledge that benefits the wider Internet community—not just ENS.

Next Steps

The ENS PG Working Group’s grant to support ICANN engagement via Emily Murray is part of our ongoing commitment to advancing public goods in the web3 ecosystem and beyond. Emily will provide regular updates to the ENS community on ICANN developments ensuring transparency and ongoing awareness of the broader Internet governance landscape. In addition, as requested, she will prepare reports that can be shared with the broader web3 community, such as key details of the new gTLD program, to ensure that members of the community can make informed decisions regarding participation in the new gTLD program and other ICANN engagement.

By funding this initiative, the ENS PG Working Group is investing in the conditions that allow decentralized Internet resources to be safely and ethically integrated with the traditional DNS. We’re proud to support efforts that increase stakeholder understanding, promote responsible advocacy, and strengthen ENS’s role as a trusted, positive force in both web3 and ICANN communities—helping to shape the future of the Internet as a public commons.

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Key Takeaways from ICANN84 in Dublin

Prepared for ENS Public Goods Working Group by Emily Murray

Members of ENS Labs and ENS DAO attended ICANN84, held in Dublin from October 25-30, 2025. Several members attended in person, with remote support provided for many sessions by Policy Consultant Emily Murray. The team’s work focused on developments relating to the new generic top-level domain (gTLD) program; activities of the Governmental Advisory Committee (GAC) and other stakeholder organizations such as the Generic Names Supporting Organization (GNSO) and Country Code Names Supporting Organization (ccNSO); sessions relating to Domain Name System (DNS) abuse and rights protection mechanisms; and ongoing discussions within the ICANN community of the relationship between the traditional DNS and Web3/blockchain domains. Please find below a summary of key takeaways from the ENS Team’s engagement in ICANN84.

High-Level Takeaways

• ICANN’s next round of new gTLDs is moving forward with the application window scheduled to launch in April 2026 (likely late April).
• The ICANN Board voted to approve the New gTLD Applicant Guidebook (AGB), which provides all of the policies and procedures for participation in the new gTLD program as an applicant or other interested party (i.e., a party who may wish to object to applications). A few pieces remain to be finalized in the AGB, but it is due to be published by December 30, 2025. (As a reminder, ENS participated extensively in the public comment process during the development of the final AGB.)
• Other than the new gTLD program, key ICANN policy priorities discussed during the meeting included: combating DNS abuse (and continuing to enhance rights protection mechanisms for doing so); and continuing to improve global ICANN engagement, particularly from historically underserved regions.
• Other than the work of the Security and Stability Advisory Committee (SSAC) Responsible Integration into the DNS Ecosystem (RIDE) Working Party, blockchain/Web3 issues were not widely discussed during formal ICANN84 sessions, except for a brief mention during the Public Forum. Accordingly, this further emphasizes the importance of continued ENS/Public Goods Working Group participation in ICANN so that Web3 issues can be better understood by the broader ICANN community and a greater cross-section of Internet users, instead of continuing to be viewed as a niche, specialized technical topic that is not relevant to most of the community. There does seem to be a great deal of interest from the general ICANN community in this topic based on conversations held during ICANN84 outside of official sessions, and thus there is room for collaboration with both ICANN staff and other stakeholders to ensure information is made available to the community from trusted, reliable sources such as ENS.

New gTLD Program Updates and Reminders

• The new gTLD program is generally on track for a launch in April 2026, likely late that month. Once the application window opens, it will likely run for about 12-15 weeks before closing in July or August 2026.
• The base application fee is confirmed at $227,000. Only organizations (not individuals) can participate as applicants in the program. Certain additional evaluation fees, ranging from a few hundred to many thousands of dollars, may be required for certain applications. Applicants may also face objections from other parties, and participation in objection proceedings may require up to tens of thousands of dollars per objection based on the costs from the 2012 application round. Also, applicants should be prepared for the possibility that their string will be in a contention set that goes to auction to the highest bidder - this could be up to millions of dollars per string. Private resolution of contention sets to avoid an auction is prohibited in this new gTLD round, however, some community members are exploring workarounds for this restriction.
• With the exception of an initial technical check of the proposed string, evaluations will not begin until the close of the application window, so there is not likely an advantage to submitting an application early in the process.
• The Applicant Support Program (ASP) remains open for a bit longer. This is a program that allows applicants with limited financial resources to apply for some support, which will amount to about an 80% reduction in new gTLD program costs, including credits toward an auction (to certain limits) if the desired string ends up in contention. Parties interested in the ASP must begin their applications by November 19 and must complete them by December 19.
• ICANN estimates that the full evaluation process will take around 14-19 months (before the first new gTLDs begin to be delegated), so the first new gTLDs from the 2026 round would not likely be added to the Internet until at least late 2027.
• Organizations that are members of the blockchain/Web3 community may be particularly interested in applying for the “.brand” type of new gTLD, in which the new gTLD extension represents a brand name and in which the new gTLD is operated for the sole benefit of the operator (domains would not be sold or offered to third parties). Please note that one requirement for this type of new gTLD is that the new gTLD string be identical to a Trademark Clearinghouse (TMCH) registration owned by the applicant. The TMCH is a rights protection mechanism implemented for the 2012 new gTLD application round. As completing an initial TMCH registration can take several months, interested organizations should begin the TMCH process as soon as possible to ensure they are eligible to apply for .brand type new gTLDs.
• The base new gTLD Registry Agreement, the contract that successful applicants will sign in order to be able to operate their gTLDs for a period of 10 years, is not quite finalized yet but should be by around March 2026. This should not delay the launch of the application window.
• The technical aspects of the string similarity review process, which will be a part of the new gTLD evaluations, are also still under development. A public comment window is open on this topic through December 4, 2025. ENS is planning to participate in this comment opportunity, particularly to advocate for the inclusion of Web3 domains in the string similarity analysis due to name collision concerns.
• Overall, most groups of ICANN stakeholders appear to be enthusiastic about the new gTLD program and are eagerly anticipating its launch in April 2026. Some ICANN84 attendees expressed concerns about program readiness in a couple areas, specifically, the technical capacity of the application system to handle the load, as well as the capacity of the GAC to review and evaluate applications quickly. Some members of the community also relayed concerns that, once again, the new gTLD program might not succeed in serving the broader global community, and that applicant representation from typically underserved regions may be less than originally hoped.

DNS Abuse and Rights Protection Mechanisms

• In addition to the new gTLD program, combating DNS abuse is a top ICANN policy priority for the coming years. ICANN recently held a public comment opportunity on its Preliminary Issue Report on this topic, in which ENS participated. The GNSO Council is currently preparing a Final Report in advance of considering moving forward with a formal Policy Development Process. Assuming ICANN does move forward with a PDP on this topic, this would be an excellent opportunity for ENS to contribute visibly to the public good by sharing its technical expertise and advocating for broader but practical and cost-effective measures to reduce DNS abuse and mitigate its effects.
• ICANN recently concluded a pilot program on its Registration Data Request Service (RDRS). Following the implementation of GDPR in 2018, Internet registrars have not been able to publish most domain registration data without the express authorization of the registrant, leading to delays in combating infringing registrations. The RDRS allowed parties with some justified need for registration data (i.e., suspected infringement, law enforcement reasons, etc.) to request this data in advance of initiating a formal dispute resolution proceeding. The RDRS pilot program had mixed results, with fewer than half of domains under management participating in the voluntary program. In addition, under 40% of requests made were actually fulfilled, with registrars often citing that they believed they were legally barred from providing the requested data. Citing a need for additional data and looking to increase participation in the program, ICANN has extended the RDRS program for two more years, through December 2025. The GAC and some other ICANN stakeholder groups have expressed concerns that a service such as RDRS will only be effective if it is mandatory, rather than voluntary; however, it appears the voluntary program will remain in place for at least two more years. ICANN has recently opened a public comment window on RDRS policy alignment, which will run through December 9, 2025. ENS may wish to consider participating in this public comment opportunity in order to contribute its technical expertise and continue to build its reputation for good citizenship in the ICANN community.
• In addition to attending official ICANN84 sessions that were part of the public program schedule, Alex Urbelis had the opportunity to attend an offsite session on DNS abuse that ICANN had organized in Dublin for law enforcement professionals, and provided a presentation and led a discussion on this topic. Accordingly, ENS is seen as a trusted source for information on DNS abuse, and this presents a further opportunity for collaboration and educating the public on why attention to this topic is essential to ensure a safe and secure Internet.

Blockchain and Web3 Discussions

• The past Annual General Meeting, held in Istanbul in November 2024, offered several sessions devoted to blockchain and Web3 issues. At that time, ICANN had expressed that there might be another focus on such issues during the 2025 Annual General Meeting. However, the ICANN84 schedule showed very minimal attention to blockchain and Web3 issues. Instead, sessions devoted to cutting-edge technologies instead focused on issues such as the use of AI in combating DNS abuse. ICANN did touch on the increasing use of country code top-level domains (ccTLDs) in cryptocurrency schemes - an issue somewhat adjacent to Web3 - but this discussion still focused on the traditional DNS.
• The Security and Stability Advisory Committee (SSAC) has formed a Working Party called RIDE (Responsible Integration into the DNS Ecosystem), which deals with the intersection of the traditional DNS and Web3. This group, which appears to be the only group formally organized by ICANN that is paying ongoing attention to Web3 issues, held a meeting in Dublin. The issues discussed in this meeting largely echoed those raised at the prior ICANN meeting, particularly that without increased attention to this matter, significant name collision issues could arise between new gTLDs added to the traditional DNS, and Web3 names. Group members cited, for example, that some web browsers now integrate access to Web3 names without special plug-ins required, and that users may face either domain resolution issues, or may be directed to domains they did not intend to access, once more new gTLDs are added to the DNS. As with the prior discussion, the meeting in Dublin raised issues and concerns more than proposing specific solutions, with all agreeing that ongoing work and study is needed. The RIDE Working Party does plan to publish a report on this topic in the first half of 2026; however, this will likely overlap with the launch of the new gTLD application round. Again, ENS should look for opportunities to amplify the voice of the RIDE Working Party, which for the moment appears to appeal to a smaller group of technical experts rather than the broader ICANN community. However, the existence and ongoing work of the RIDE Working Party does lend further legitimacy to ENS and the Public Goods Working Group’s advocacy points, such that the concerns we express are not solely coming from outsiders.
• @clowes.eth also attended the RIDE Working Party meeting and contributed his technical expertise to the discussion, and has been invited to explore future collaborations with the group.
• Participants in the Public Forum, during which members of the community can ask questions of the ICANN Board and executive team, did also bring up Web3 issues briefly, particularly asking about how the intersection of Web3 and the traditional DNS might impact ICANN compliance matters and service obligations for Internet registries. No definitive response was provided from ICANN leadership, but this is an issue to continue monitoring for further discussion and potential advocacy.
• Overall, the biggest concerns from other ICANN stakeholders regarding Web3 as highlighted by @simona_pop seem to be:

• Language vs. mechanics: ENS’ constitutional language about not infringing name-owner rights can sound like “perpetuity,” even though the mechanics are term-limited with expiry. That messaging gap alone is triggering policy anxiety.
• Dispute resolution parity: Without a built-in, binding UDRP-style pathway, brands and rights-holders lack a familiar, enforceable mechanism to recover abusive registrations. That’s a notable divergence from ICANN norms.
• Governance priorities: "Integrate with DNS without sacrificing decentralization” is philosophically sound for web3, but for ICANN it raises the question: When these values collide, who yields?

Next Steps for ENS and the Public Goods Working Group

• Monitor and review public comments submitted by third parties in the Proposed Next Round Base gTLD Registry Agreement public comment window, due to close on November 17, 2025, and review the final Base gTLD Registry Agreement when published.
• Prepare and submit comments for the String Similarity Evaluation Data for New gTLD Program: Next Round public comment opportunity, due by December 4, 2025.
• Consider the opportunity to prepare and submit comments for the Registration Data Request Service (RDRS) Policy Alignment Analysis public comment opportunity, due by December 9, 2025.
• Prepare Venn diagrams illustrating what a collaborative approach would look like between ENS/the public goods community and various ICANN stakeholders, in particular, looking at areas of overlap and opportunities for closer collaboration and alignment.
• Conduct a detailed analysis of the final New gTLD Applicant Guidebook (AGB) when published, anticipated by December 30, 2025.
• Develop outreach strategy to educate other blockchain/Web3 organizations that may not currently be participating in ICANN about the new gTLD program opportunity.
• Monitor for publication of the public comment report on the Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation (ENS recently submitted public comments on this topic; ICANN’s report should be published in the coming weeks), as well as continue monitoring for additional developments in connection with a potential formal Policy Development Process on this topic.
• Evaluate opportunities to participate in the SSAC RIDE Working Party or to amplify the voice of this group, to ensure that blockchain/Web3 issues remain on the radar for the broader ICANN community.
• Begin preparations for ICANN85 in Mumbai, which will be held from March 7-12, 2026.