{ "schema": "1.1", "methodologyVersion": "1.0", "date": "2026-07-23", "nextReviewBy": "2026-10-23", "reviewNote": "A review is also due within 14 days of the InternetNZ AGM on 13 August 2026, or of any other material public event.", "site": { "title": "redelegate.nz", "tagline": "Independent risk scorecard for potential re-delegation of the .nz ccTLD", "subtitle": "Measuring formal process risk under the 2016 MBIE–InternetNZ MoU (clauses 29–35) and RFC 1591 — not ambient politics." }, "record": { "zone": ".nz", "manager": "Internet New Zealand Inc. (InternetNZ)", "delegated": "1996 · chosen by the local internet community", "framework": "RFC 1591 · 2016 MBIE–InternetNZ MoU (cl. 29–35)", "mouStatus": "No formal concerns raised", "altManager": "None proposed" }, "conditions": [ { "clause": "MoU cl. 33(a)", "title": "Clear consensus that InternetNZ is managing .nz inconsistently with RFC 1591", "met": false, "status": "Not met", "where": "Criticism exists and is scored honestly (A: Moderate, B: Moderate) — but it is nowhere near community consensus, and no concern has ever been raised through the formal MoU channel (C: Low)." }, { "clause": "MoU cl. 33(b)", "title": "Clear consensus that a better local manager exists and will manage .nz consistently with RFC 1591", "met": false, "status": "Not met", "where": "No organisation has publicly proposed to take over .nz — not even InternetNZ’s strongest critics, whose strategy is to win seats inside it (E: Low)." } ], "dimensions": { "A": { "id": "A", "name": "Consistency with RFC 1591", "short": "RFC 1591 consistency", "weight": "High", "weightNote": "One of the two required conditions for re-delegation", "score": 2, "label": "Moderate", "oneLiner": "Credible public criticism of the content-neutrality direction, and one isolated 2023 operational incident — but no documented case of content-based registration action and no systemic issues.", "justification": "There is real, well-documented criticism: the 2025 constitution debate produced credible public claims (Free Speech Union, national media) that InternetNZ’s direction could threaten the “no concern for use” principle, and a May 2023 DNSSEC chain-validation incident affected some .ac.nz domains. Against that: InternetNZ publicly committed that it has no plans to regulate .nz on the basis of content; there is no documented case of a .nz registration being refused, suspended or cancelled on content or viewpoint grounds outside published policy; .nz Rules continue to apply first-come-first-served registration; and the registry has operated stably since the 2023 incident, which was transparently post-mortemed. Under the methodology this is isolated criticism without documented systemic issues: Moderate, driven by sub-criterion A3.", "wouldRaise": "Documented cases of content- or viewpoint-based refusal, suspension or cancellation outside published policy; a pattern of operational failures; credible evidence of InternetNZ treating .nz as property rather than a public trust.", "subScores": [ { "id": "A1", "name": "Equitable treatment", "desc": "Registration, renewal, transfer and enforcement applied equitably", "score": 1, "note": "First-come-first-served rules; DNCL enforcement follows published policy. No documented pattern of differential treatment." }, { "id": "A2", "name": "Technical competence", "desc": "Operational stability of registry and DNS", "score": 1, "note": "One isolated incident (May 2023 DNSSEC chain validation, .ac.nz) with a public technical post-mortem; stable operation since. Watch item, not a pattern." }, { "id": "A3", "name": "Content neutrality", "desc": "Continued adherence to the “no concern for use” principle", "score": 2, "note": "Credible public criticism of direction during the 2025 constitution debate; InternetNZ publicly disavowed content regulation. No documented content-based registration action." }, { "id": "A4", "name": "Trustee role", "desc": "Manager acting as trustee, not treating the domain as property", "score": 1, "note": "No public evidence of trustee-duty breach. Surplus use is publicly reported." } ], "evidence": [ { "title": "RNZ — Censorship fears over revamp of InternetNZ’s constitution (Feb 2025)", "url": "https://www.rnz.co.nz/news/national/543148/censorship-fears-over-revamp-of-internetnz-s-constitution" }, { "title": "InternetNZ — “InternetNZ corrects misinformation” (2025)", "url": "https://internetnz.nz/news-and-articles/internetnz-corrects-misinformation/" }, { "title": "InternetNZ — DNSSEC chain validation issue: technical incident report (2023)", "url": "https://internetnz.nz/news-and-articles/dnssec-chain-validation-issue-technical-incident-report/" }, { "title": "InternetNZ — .nz Agreements 2025 (Rules v3.2 in force 17 Mar 2026)", "url": "https://docs.internetnz.nz/registry/Agreements_2025/" }, { "title": "RFC 1591 — Domain Name System Structure and Delegation (1994)", "url": "https://datatracker.ietf.org/doc/html/rfc1591" }, { "title": "The Register — Membership of New Zealand’s domain registry suddenly triples (Mar 2025)", "url": "https://www.theregister.com/2025/03/01/internetnz_constitution/" } ], "evidenceTypes": ["Published .nz Rules", "DNCL enforcement data", "Registry performance reports", "Documented cases of differential treatment", "IANA root zone data", "Independent technical assessments"], "scoringGuidance": [ { "score": 1, "text": "No public evidence of problems." }, { "score": 2, "text": "Isolated criticism without documented systemic issues." }, { "score": 3, "text": "Multiple credible examples of inequitable treatment or clear operational problems." }, { "score": 4, "text": "Strong evidence of systemic inconsistency with RFC 1591 trustee / equity / competence duties." } ] }, "B": { "id": "B", "name": "Local Internet Community Confidence", "short": "Community confidence", "weight": "High", "weightNote": "Supports the “significantly interested parties” and trustee standards", "score": 2, "label": "Moderate", "oneLiner": "Documented polarisation — a 5× membership surge in protest, a critic elected to the board — but the constitution passed with over 80% of votes cast and every opposing amendment was defeated.", "justification": "Polarisation is real and on the record: in early 2025, campaigns by the Free Speech Union and Hobson’s Pledge swelled InternetNZ’s membership from under 400 to over 2,000, largely in opposition to the proposed Te Tiriti-centric constitution, with sustained national media coverage. FSU chief executive Jonathan Ayling was elected to the board at the 31 July 2025 AGM (929 votes). But significant support demonstrably remains across major stakeholder groups: the new constitution was adopted on 10 April 2025 with more than four in five votes cast in favour; every FSU constitutional amendment was defeated at the 2025 AGM; the top-polling 2025 candidate (Dylan Reeve, 1,372 votes) was not FSU-aligned; and turnout was strong at 62.4%. No registrar body, technical operator group, government agency or Māori internet organisation has publicly questioned InternetNZ’s legitimacy as .nz manager. This is exactly the methodology’s definition of Moderate.", "wouldRaise": "Multiple independent stakeholder groups — beyond a single advocacy campaign and its members — publicly questioning InternetNZ’s role as .nz manager; majority-level loss-of-confidence outcomes in member votes.", "subScores": [], "evidence": [ { "title": "NZ Herald — InternetNZ sees an explosion in membership as Free Speech Union angles for control (2025)", "url": "https://www.nzherald.co.nz/business/tech-insider-internetnz-sees-an-explosion-in-membership-as-free-speech-union-angles-for-control-but-will-it-be-snookered-by-voting-rules-new-constitution/RA2APDIMVNDKXLRDCDHVR5EXPY/" }, { "title": "NZ Herald — FSU’s bid to reshape InternetNZ: the results are in, with a late twist (Aug 2025)", "url": "https://www.nzherald.co.nz/business/free-speech-unions-bid-to-reshape-internetnz-the-results-are-in-with-a-late-twist-tech-insider/5BLAOPUL4JCCVALF442AGZPJY4/" }, { "title": "InternetNZ — 2025 Annual General Meeting (results and minutes)", "url": "https://internetnz.nz/governance-and-reports/our-board/2025-annual-general-meeting/" }, { "title": "Scoop — Jonathan Ayling voted onto InternetNZ board (Aug 2025)", "url": "https://www.scoop.co.nz/stories/AK2508/S00003/jonathan-ayling-voted-onto-internetnz-board-work-starts-to-restore-respect-for-free-speech.htm" }, { "title": "The Spinoff — InternetNZ shouldn’t be the battleground of a free speech culture war (Mar 2025)", "url": "https://thespinoff.co.nz/internet/04-03-2025/internetnz-shouldnt-be-the-battleground-of-a-free-speech-inspired-culture-war" }, { "title": "The Post — Only about 360 of InternetNZ’s burgeoning membership will get vote on new constitution (2025)", "url": "https://www.thepress.co.nz/business/360610708/only-about-360-internetnzs-burgeoning-membership-will-get-vote-new-constitution" } ], "evidenceTypes": ["Membership data", "Public statements from diverse stakeholder groups", "Formal complaints", "Survey results", "Outcomes of major member votes", "Breadth of organisations expressing loss of confidence"], "scoringGuidance": [ { "score": 1, "text": "Broad confidence appears intact." }, { "score": 2, "text": "Polarisation exists but significant support remains across major stakeholder groups." }, { "score": 3, "text": "Multiple independent stakeholder groups publicly question the manager’s legitimacy." }, { "score": 4, "text": "Clear evidence of majority or consensus-level loss of confidence across the local Internet community." } ] }, "C": { "id": "C", "name": "MoU Formal Process Status", "short": "MoU process status", "weight": "Critical", "weightNote": "Gatekeeper dimension — if C is Low, overall risk stays Low", "score": 1, "label": "Low", "oneLiner": "No step under MoU clauses 29–35 has ever been taken. The only recorded MoU activity — an August 2025 update to Appendix 1 — was a contact-details change under clause 25.", "justification": "There is no public evidence of any step under the MoU’s concern-resolution process: no clause 30 request for explanation or meeting, no clause 32 notification of RFC 1591 concerns, and no clause 33 multi-stakeholder conversation. MBIE made no public statement of concern during the 2025 constitution controversy. The only recorded MoU activity in the period is the August 2025 amendment of Appendix 1 — which, per the note on the document itself, was made “pursuant to clause 25 of this MoU — to update contact details.” That is routine administration and evidence the relationship is functioning normally, not evidence of a concerns process.", "wouldRaise": "Publication of MBIE (or other significantly interested party) correspondence raising concerns about .nz management; a clause 30 meeting request; any move to initiate a clause 33 multi-stakeholder conversation.", "subScores": [], "evidence": [ { "title": "MBIE–InternetNZ MoU (2016), with Appendix 1 as amended August 2025 — full text", "url": "https://internetnz.nz/assets/MBIE-InternetNZ-MoU-2016-with-amended-Appendix-1-August-2025.pdf" }, { "title": "MBIE — copy of the 2016 MoU", "url": "https://www.mbie.govt.nz/dmsdocument/1178-internetnz-mbie-mou-dotnz-pdf" }, { "title": "Beehive — New agreement strengthens management of .nz domain name (May 2016)", "url": "https://www.beehive.govt.nz/release/new-agreement-strengthens-management-nz-domain-name" }, { "title": "IANA — Root zone database record for .nz", "url": "https://www.iana.org/domains/root/db/nz.html" }, { "title": "ccNSO — Framework of Interpretation for delegation and re-delegation of ccTLDs (2014)", "url": "https://itp.cdn.icann.org/en/files/council/foi-final-07oct14-en.pdf" } ], "evidenceTypes": ["Official correspondence from MBIE or other significantly interested parties", "Public records of meetings", "Initiation of multi-stakeholder conversation", "Any formal steps toward IANA"], "scoringGuidance": [ { "score": 1, "text": "No formal concerns have been raised under the MoU process." }, { "score": 2, "text": "Informal or preliminary discussions have occurred." }, { "score": 3, "text": "Formal written concerns have been raised and the response/meeting process is underway." }, { "score": 4, "text": "An open multi-stakeholder conversation seeking clear consensus has been initiated or is in progress." } ] }, "D": { "id": "D", "name": "Transparency & Community Engagement", "short": "Transparency & engagement", "weight": "Supporting", "weightNote": "MoU clauses 26–27 — supporting dimension", "score": 1, "label": "Low", "oneLiner": "The specific clause 26–27 commitments — timely annual reports, published minutes, surplus reporting, broad consultation — all appear delivered.", "justification": "Scored on delivery against the specific MoU commitments: annual reports are published and audited accounts presented at AGMs; board meeting packs and minutes are published; quarterly activity reports are public (e.g. Q1 2025–26); surplus-funded activity is publicly reported; and the change to InternetNZ’s constitution — a change to its objects — went through multi-round public consultation with published FAQs, exactly what clause 26(d) requires. Criticism that only members of standing (roughly 360 of the surged membership) could vote on the constitution concerned membership eligibility rules, not MoU transparency commitments; it is noted as a monitoring item under Dimension B.", "wouldRaise": "Late or missing annual reports; ceasing publication of board minutes; major .nz policy changes made without consultation; ending public reporting on surplus-funded activities.", "subScores": [], "evidence": [ { "title": "InternetNZ — Activity Report Q1 2025–2026", "url": "https://internetnz.nz/governance-and-reports/plans-and-reports/activity-report-q1-20252026/" }, { "title": "InternetNZ — 2025 Annual General Meeting (audited accounts, minutes)", "url": "https://internetnz.nz/governance-and-reports/our-board/2025-annual-general-meeting/" }, { "title": "InternetNZ — Proposed constitution released (consultation record)", "url": "https://internetnz.nz/news-and-articles/internetnzs-proposed-constitution-released/" }, { "title": "InternetNZ — Constitution FAQs", "url": "https://internetnz.nz/governance-and-reports/governance-documents/constitution-faqs/" }, { "title": "InternetNZ — Our Board (meeting packs and minutes)", "url": "https://internetnz.nz/governance-and-reports/our-board/" } ], "evidenceTypes": ["Timeliness of annual reports", "Publication of Board minutes", "Public reporting on surplus activities", "Quality of consultations", "Evidence of testing broader community views"], "scoringGuidance": [ { "score": 1, "text": "Commitments appear met; no material concern." }, { "score": 2, "text": "Isolated delays or gaps against published commitments." }, { "score": 3, "text": "Systemic shortfalls in delivery against MoU transparency duties." }, { "score": 4, "text": "Sustained, documented failure to meet MoU engagement and reporting commitments." } ] }, "E": { "id": "E", "name": "Credible Alternative Manager", "short": "Alternative manager", "weight": "High", "weightNote": "Second required condition — if E is Low, overall cannot exceed Moderate", "score": 1, "label": "Low", "oneLiner": "No organisation has proposed to replace InternetNZ. Its strongest critics chose to run for its board — a strategy that presupposes InternetNZ remains the manager.", "justification": "No alternative manager has been publicly proposed, speculatively or otherwise. The most organised critical campaign — the Free Speech Union’s — pursued membership drives, board candidacies and constitutional amendments: change from within, which presupposes InternetNZ remains the designated manager. No entity has demonstrated technical capability or readiness to accept transfer of the register and zones, and no stakeholder statements of support for any alternative exist.", "wouldRaise": "A concrete public proposal from an organisation with demonstrated registry capability; statements of support for that alternative from a broad range of stakeholders; demonstrated readiness to accept transfer of the register and zones.", "subScores": [], "evidence": [ { "title": "Scoop — FSU nominates InternetNZ board candidates and proposes constitution (Jul 2025)", "url": "https://www.scoop.co.nz/stories/PO2507/S00044/fsu-nominates-internetnz-board-candidates-and-proposes-constitution-to-defend-online-speech.htm" }, { "title": "InternetNZ — 2026 Board elections (two seats; nominations closed 16 Jul 2026)", "url": "https://internetnz.nz/governance-and-reports/our-board/board-elections/2026-board-elections/" }, { "title": "IANA — Root zone database record for .nz (InternetNZ remains sponsoring organisation)", "url": "https://www.iana.org/domains/root/db/nz.html" } ], "evidenceTypes": ["Public proposals from alternative organisations", "Demonstrated technical capability", "Statements of support from a broad range of stakeholders", "Readiness to accept transfer of register and zones"], "scoringGuidance": [ { "score": 1, "text": "No credible alternative has been publicly proposed." }, { "score": 2, "text": "Speculative alternatives exist without broad support or readiness." }, { "score": 3, "text": "A specific alternative has been proposed with some stakeholder support and basic capability." }, { "score": 4, "text": "A ready, competent alternative has clear and broad community support." } ] } }, "overall": { "score": 1, "label": "Low", "rule": 1, "justification": "Rule 1 applies: no step under the MoU concerns process (clauses 29–35) has been taken, so Dimension C is Low and overall risk is Low — evaluation stops there. Independently, no alternative manager exists (E: Low caps the score at Moderate) and neither required condition is above Moderate (A ≤ 2 and B ≤ 2)." }, "timeline": [ { "date": "May 2016", "title": "MBIE–InternetNZ MoU signed", "body": "MBIE and InternetNZ, as “two significantly interested parties,” agree the modern framework for .nz. Clauses 29–35 define the only formal path to re-delegation: notify concerns, allow time to respond, then an open multi-stakeholder conversation seeking clear consensus on two conditions.", "impact": "Defines what this scorecard measures", "kind": "neutral" }, { "date": "2021–2022", "title": "Systemic racism review", "body": "Following the 2021 resignation of Māori council members, an independent review finds systemic racism in InternetNZ’s organisational culture. It becomes the impetus for the governance reform that produced the 2025 constitution.", "impact": "Context for later reform · not a formal process step", "kind": "neutral" }, { "date": "Nov 2022", "title": "New registry platform goes live", "body": "The InternetNZ Registry System (IRS), based on software from Canada’s CIRA, replaces the in-house SRS platform.", "impact": "Background to the A2 watch item", "kind": "neutral" }, { "date": "May 2023", "title": "DNSSEC validation incident (.ac.nz)", "body": "A key-rotation misalignment causes DNSSEC validation failures for some .ac.nz domains. InternetNZ publishes a technical incident report. No recurrence on the public record since.", "impact": "Noted under A2 · isolated, transparently reported", "kind": "watch" }, { "date": "Feb–Mar 2025", "title": "Constitution backlash — membership surges 5×", "body": "A proposed Te Tiriti-centric constitution triggers campaigns by the Free Speech Union and Hobson’s Pledge warning of censorship. Membership jumps from under 400 to over 2,000. RNZ, NZ Herald and The Register cover the fight; InternetNZ publicly rebuts “misinformation” and notes DNS is a poor tool for censorship.", "impact": "B raised to Moderate · A3 watch item", "kind": "raise" }, { "date": "10 Apr 2025", "title": "New constitution adopted", "body": "More than four in five votes cast favour the new constitution, including Te Tiriti commitments and a move to appointed as well as elected board seats.", "impact": "Evidence that broad support remains · B stays Moderate", "kind": "neutral" }, { "date": "8 Jul 2025", "title": "FSU contests the board — from within", "body": "The Free Speech Union nominates CEO Jonathan Ayling and lawyer Douglas Brown for the board and proposes constitutional amendments. The strategy is reform from within — it presupposes InternetNZ remains .nz’s manager.", "impact": "Evidence for E staying Low", "kind": "neutral" }, { "date": "31 Jul 2025", "title": "AGM delivers a split verdict", "body": "Ayling is elected with 929 votes alongside top-polling Dylan Reeve (1,372, not FSU-aligned); Brown misses out. Every FSU constitutional amendment is defeated. Turnout: 62.4% of eligible members.", "impact": "Polarisation and continuing broad support both confirmed · B stays Moderate", "kind": "neutral" }, { "date": "Aug 2025", "title": "MoU Appendix 1 updated — contact details only", "body": "The only recorded MoU activity of the period. The document’s own note: amended “pursuant to clause 25 of this MoU — to update contact details.” Routine administration, not a concerns process.", "impact": "C stays Low", "kind": "neutral" }, { "date": "17 Mar 2026", "title": ".nz Rules v3.2 come into force", "body": "Updated agreements strengthen accountability mechanisms across the registry–registrar chain, delivered through the standard open policy process.", "impact": "Consistent with A1 and D at current levels", "kind": "neutral" }, { "date": "Jun–Aug 2026", "title": "Board reshapes under the new constitution", "body": "The board reduces from 11 to 9 members. Two appointed members — Dr Darryn Russell and Dr Keri Milne-Ihimaera — join after the 13 August 2026 AGM. Elections for two seats are underway (nominations closed 16 July 2026).", "impact": "Scorecard review due within 14 days of the AGM", "kind": "watch" } ], "history": [ { "date": "2026-07-23", "version": "1.0", "note": "Initial baseline published, all dimensions set conservatively to Low pending the first full evidence review.", "overall": 1, "dimensions": { "A": 1, "B": 1, "C": 1, "D": 1, "E": 1 } }, { "date": "2026-07-23", "version": "1.1", "note": "First full evidence review. A raised to Moderate (A3: credible criticism of content-neutrality direction during the 2025 constitution debate). B raised to Moderate (documented polarisation; broad support remains). C, D, E confirmed Low with evidence. Overall unchanged: Low.", "overall": 1, "dimensions": { "A": 2, "B": 2, "C": 1, "D": 1, "E": 1 } } ], "principles": [ { "title": "Two conditions, both required", "body": "Re-delegation requires clear multi-stakeholder consensus that InternetNZ is managing .nz inconsistently with RFC 1591, and that a better local manager exists who will manage it consistently with RFC 1591." }, { "title": "Criticism is not process risk", "body": "Ambient criticism, advocacy disagreement, or membership polarisation alone is insufficient to raise overall risk above Moderate." }, { "title": "Evidence or it doesn’t count", "body": "Every score must be supported by publicly verifiable evidence. No evidence means N/A or Low, as appropriate." }, { "title": "Conservative by design", "body": "The overall score deliberately respects the high formal bar for re-delegation. Dimensions are never averaged — gate rules decide." } ], "updateProcess": [ "Review at least once per quarter.", "Review within 14 days of any material public event (formal MBIE letter, major membership vote, IANA communication, new alternative proposal, etc.).", "Every update records previous scores, new scores, evidence (with links), and a short justification for any change.", "All historical scores and justifications remain publicly available." ] }