Report on the Transfer of the .BY top-level domain and the .бел (“bel”) top-level domain representing Belarus to Belarusian Cloud Technologies LLC
27 May 2022
This report summarizes the materials reviewed as part of the process for the transfer of the .BY and .бел ("bel") top-level domains, representing Belarus in ASCII and Cyrillic respectively. It includes details regarding the proposed transfer, evaluation of the documentation pertinent to the request, and actions undertaken to process the transfer.
Factual Information
Country
The “BY” ISO 3166-1 code from which the application’s eligibility derives is designated for use to represent Belarus.
Chronology of events
The .BY top-level domain was initially delegated in 1994 to Open Contact Ltd.
In October 1999, the management of .BY was transferred to the State Centre of Security Information of Belarus.
In 2008, in accordance with Presidential Decree No. 229, the State Centre of Security Information ceased to exist and was replaced by the Operational and Analytical Center (OAC). Based on the decree, all the rights and duties of the previous entity were assumed by OAC.
In March 2009, management of the .BY top-level domain was transferred back to Open Contact Ltd. and OAC was designated as its administrative contact.
On 1 February 2010, Article 13 of Presidential Decree No. 60 named OAC the authorized government body for Internet security.
On 18 June 2010, OAC issued Executive Order No. 47, “Instruction on the Registration of Domain Names in the National Domain Zone,” giving itself the responsibility for appointing the “technical administrator of the national domain zone.” Among other duties, the order instructs the “technical administrator of the national domain zone” to “ensure the functioning of the national domain zone, including the maintenance of a database, the use of the necessary software and hardware, information technologies and infrastructure for these purposes, and create and maintain the conditions for the proper delegation of domain names registered in the national domain zone.”
On 30 September 2010, Presidential Decree No. 515, "On Some Measures to Develop the Data Transfer Networks," appointed OAC as the independent regulator of information and communication technologies. Accordingly, OAC has served as the administrative contact for the .BY and .бел top-level domains and is responsible for developing their registration policies.
In 2012, management of the .BY top-level domain was transferred to Reliable Software, Inc., the organization selected by OAC to be the “technical administrator of the national domain zone”.
On 19 December 2012, Belarusian Cloud Technologies LLC. (hereinafter beCloud LLC.) was founded and began providing Internet services.
In 2014, the IDN Fast Track application to have the string "бел" recognized as the Cyrillic representation of Belarus was approved.
In 2015, the .бел top-level domain was delegated to Reliable Software, Inc.
In 2019, beCloud LLC. became a domain name registrar and started providing registration services for the .BY and .бел top-level domains.
On 25 August 2021, OAC issued Order No. 138, "On Administration of the National Domain Zone," and appointed beCloud as the new “technical administrator of the national domain zone”, effective 1 January 2022.
On 29 December 2021, beCloud LLC. initiated a transfer request for the .BY and .бел top-level domains.
Proposed Manager and Contacts
The proposed manager is Belarusian Cloud Technologies LLC., a company registered in 2012 in the database of the Single State Register of Legal Entities and Individual Entrepreneurs of the Ministry of Justice of the Republic of Belarus (registration no. 191772685). It is located in Minsk, Belarus.
The administrative contact is not changing as a part of this transfer. Kiril Mordan, Head Specialist at OAC, will remain in this role.
The proposed technical contact is Aleh Siadzelnik, General Director of beCloud LLC.
Evaluation of the Request
String Eligibility
The top-level domains are eligible for transfer as the two-letter string "BY" is presently listed in the ISO 3166-1 standard for Belarus and the string "бел" has been deemed an appropriate representation of Belarus through the ICANN Fast Track String Selection process.
Incumbent Consent
The incumbent manager is Reliable Software, Ltd. Informed consent for the transfer of the .BY and .бел ("bel") top-level domains to beCloud was provided by Sergei Povalishev, Chief Executive Officer of Reliable Software, Ltd.
Public Interest
Sergei Vasilievich Zhernosek, Deputy Head of OAC, provided a letter of explicit government support for the transfers. OAC is the government entity with regulatory powers concerning the .BY and .бел top-level domains.
Additional support was provided by the following significantly interested parties:
- Voronin P.S., Director of Support Chain, LLC, an organization that is involved in domain name registration activities in Belarus.
- D. Hatsko, Chief Legal Officer of Aktivnie Tehnologii, LLC, a domain name registrar in Belarus.
- Natallia Medvedova, First Deputy Director of Open Contact, LLC, a domain name registrar in Belarus.
- Igor Starovoitov, Deputy Director of TriIncom, LLC, a hosting service provider and domain name registrar in Belarus.
- S. Bogdanov, CEO of the Association of Information and Communication Technology Organizations "Belinfocom", a nonprofit, voluntary association of commercial organizations and individuals engaged in entrepreneurial activities in information and communication technology.
- Vladimir Basko, Chairman of the Digital Business Confederation, an association aiming to consolidate efforts to develop the digital market and digital businesses in Belarus.
The application is consistent with known applicable laws in Belarus. The proposed manager undertakes the responsibility to operate the domain in a fair and equitable manner.
Based in Country
The proposed manager is constituted in Belarus. The administrative contact is understood to be a resident of Belarus.
Stability
The application is not known to be contested.
We have not identified any stability issues with this request.
Competency
The application has provided information on the technical and operational infrastructures and expertise that will be used to operate the domain.
Proposed policies for management of the domain have also been tendered.
Evaluation Procedure
PTI is tasked with coordinating the Domain Name System root zone as part of a set of functions governed by a contract with ICANN. This includes accepting and evaluating requests for delegation and transfer of top-level domains.
A subset of top-level domains are designated for the significantly interested parties in countries to operate in a way that best suits their local needs. These are known as country-code top-level domains (ccTLDs), and are assigned to responsible managers that meet a number of public-interest criteria for eligibility. These criteria largely relate to the level of support the manager has from its local Internet community, its capacity to ensure stable operation of the domain, and its applicability under any relevant local laws.
Through the IANA Services performed by PTI, requests are received for delegating new ccTLDs, and transferring or revoking existing ccTLDs. An investigation is performed on the circumstances pertinent to those requests, and the requests are implemented where they are found to meet the criteria.
Purpose of Evaluations
The evaluation of eligibility for ccTLDs, and of evaluating responsible managers charged with operating them, is guided by a number of principles. The objective of the assessment is that the action enhances the secure and stable operation of the Internet’s unique identifier systems.
In considering requests to delegate or transfer ccTLDs, input is sought regarding the proposed new manager, as well as from persons and organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated. The assessment is focused on the capacity for the proposed manager to meet the following criteria:
• The domain should be operated within the country, including having its manager and administrative contact based in the country.
• The domain should be operated in a way that is fair and equitable to all groups in the local Internet community.
• Significantly interested parties in the domain should agree that the prospective manager is the appropriate party to be responsible for the domain, with the desires of the national government taken very seriously.
• The domain must be operated competently, both technically and operationally. Management of the domain should adhere to relevant technical standards and community best practices.
• Risks to the stability of the Internet addressing system must be adequately considered and addressed, particularly with regard to how existing identifiers will continue to function.
Method of Evaluation
To assess these criteria, information is requested from the applicant regarding the proposed manager and method of operation. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, various documentation is sought describing: the views of the local internet community on the application; the competencies and skills of the manager to operate the domain; the legal authenticity, status and character of the proposed manager; and the nature of government support for the proposal.
After receiving this documentation and input, it is analyzed in relation to existing root zone management procedures, seeking input from parties both related to as well as independent of the proposed manager should the information provided in the original application be deficient. The applicant is given the opportunity to cure any deficiencies before a final assessment is made.
Once all the documentation has been received, various technical checks are performed on the proposed manager’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries correctly. Should any anomalies be detected, PTI will work with the applicant to address the issues.
Assuming all issues are resolved, an assessment is compiled providing all relevant details regarding the proposed manager and its suitability to operate the relevant top-level domain.