Introduction

As the next round of new generic top-level domain (gTLD) applications approaches in 2026, the Registry Service Provider (RSP) Evaluation Program introduced by ICANN is redefining the technical and legal foundations of the domain name ecosystem.

This program marks a structural shift in how registry operators are assessed, certified, and integrated into the global DNS infrastructure. For trademark owners, intellectual property professionals, registries, understanding this framework is now a strategic imperative.

Understanding the registry service provider evaluation program

A new model for technical qualification

The RSP Evaluation Program introduces a decoupled assessment model, separating technical validation from individual gTLD applications.

Under the former framework, each applicant had to demonstrate independently its operational capabilities. This approach generated:

  • Redundant technical audits
  • Increased compliance costs
  • Extended review timelines
  • Inconsistent quality benchmarks

The RSP model replaces this with a centralized pre-qualification mechanism, whereby providers are evaluated once and recognized across multiple applications.

Core services covered by the RSP framework

Certified RSPs must demonstrate robust capacity in:

  • Domain Name System (DNS) operations
  • DNSSEC key management and cryptographic security
  • Registry data publication and RDAP compliance
  • Registry system continuity and disaster recovery
  • Escrow and data integrity mechanisms

These functions are no longer treated as ancillary. They now constitute the technical backbone of gTLD governance.

Evaluation phases and operational framework

Pre-evaluation phase (2024–2025)

The initial pre-evaluation phase enabled early applicants to undergo technical assessment ahead of the main round.

Its objectives included:

  • Establishing a pool of vetted operators
  • Enhancing transparency for applicants
  • Facilitating early contractual negotiations

Successful candidates are listed publicly, creating a reference market for future applicants.

Concurrent evaluation phase (From 2026)

A second evaluation window will operate alongside the 2026 gTLD application round.

This phase targets:

  • New entrants
  • Late technical providers
  • Applicants developing in-house registry systems

phase evaluation providers

Testing infrastructure: OT&E and RST v2.0

ICANN’s Operational Test and Evaluation (OT&E) and Registry System Testing (RST) v2.0 environments are mandatory validation platforms established to verify that a registry operator or RSP provider is genuinely capable of managing a top-level domain in a reliable, secure, and continuous manner.

They assess:

  • Load resilience
  • Incident response capacity
  • Data recovery procedures
  • System interoperability

This reinforces operational reliability at the root of DNS governance.

Legal and technical implications for stakeholders

Technical reliability as a legal safeguard

From an IP enforcement perspective, registry stability directly conditions the effectiveness of:

Without a qualified RSP, these instruments lose practical effectiveness.

Impact on enforcement and dispute resolution

Procedures administered in coordination with institutions such as the WIPO depend on accurate registry data and operational continuity.

A certified RSP ensures:

  • Reliable registrant identification
  • Traceable abuse reporting
  • Preservation of evidentiary records

These elements are decisive in litigation and administrative proceedings.

Strategic opportunities for trademark owners and rights holders

Cost rationalization and budget predictability

The pre-certification model significantly reduces:

  • Technical audit expenses
  • Legal contingency reserves
  • Emergency remediation costs

Applicants can reallocate resources toward:

  • Trademark architecture
  • Defensive registration programs
  • Digital compliance policies

Enhancing .trademark governance models

For corporate applicants pursuing .trademark strategies, RSP certification enables:

  • Centralized trademark ecosystems
  • Controlled distribution channels
  • Unified cybersecurity governance
  • Integrated compliance frameworks

Practical recommendations for 2026 applicants

We recommend that applicants integrate RSP considerations into early strategic planning.

Key action points

  • Identify pre-evaluated RSPs at least 18 months in advance
  • Integrate RSP timelines into trademark filing strategies
  • Conduct legal audits of registry agreements
  • Align DNS governance with trademark protection policies
  • Establish internal oversight committees

Internal and external resource integration

Applicants should coordinate:

  • Legal teams
  • IT governance units
  • Cybersecurity departments
  • External IP counsel
  • Registry operators

This transversal approach reduces operational fragmentation.

Conclusion

The Registry Service Provider Evaluation Program represents a structural evolution in DNS governance. It transforms technical qualification into a strategic legal instrument and places infrastructure reliability at the center of trademark protection.

For domain name stakeholders, this program is no longer optional. It is a prerequisite for sustainable digital positioning.

The Registry Service Provider Evaluation Program must now be understood as a cornerstone of modern domain name strategy.

Dreyfus & Associés assists its clients in managing complex intellectual property cases, offering personalized advice and comprehensive operational support for the complete protection of intellectual property.

Dreyfus & Associés works in partnership with a global network of attorneys specializing in Intellectual Property.

Nathalie Dreyfus with the support of the entire Dreyfus team

FAQ

1. Does RSP certification guarantee application approval?
No. It only validates technical capacity. Legal, financial, and policy reviews remain applicable.

2. How long does RSP evaluation usually take?
Between 6 and 12 months, depending on system complexity and remediation requirements.

3. Should trademark owners prioritize pre-evaluated providers?
Yes. Early engagement reduces regulatory and operational uncertainty.

4. What are the main legal risks of using a non-certified provider?
Application rejection, enforcement failures, compliance breaches, and reputational damage.

5. When should applicants begin RSP negotiations?
Ideally 24 months before the application window.

This publication is intended for general public guidance and to highlight issues. It is not intended to apply to specific circumstances or to constitute legal advice.