Allow AS Number Transfers

Summary of Proposal

According to the RIPE Document, “Autonomous System (AS) Number Assignment Policies”, it is not possible to transfer Autonomous System (AS) numbers.

There are operational cases that are not mergers or acquisitions but rather transfers of resources, which might drive LIR’s into a corner when deciding to consolidate LIRs or companies. This is because they would either have to return their AS Numbers that can’t be transferred, or lie to the RIPE NCC that this was a merger or acquisition instead of a transfer or consolidation.

By allowing the option to transfer an AS Number from one company entity to another, it will be easier to keep the infrastructure for services and history intact, like the peering agreements after the transition of services from one company to another.

An adjustment was made to section 3.0, which describes the current mandatory return of unused AS Numbers. By using the term “should” according to RFC 2119 this requirement is kept, but it can be ignored for valid reasons such as an upcoming transfer.

The goal of this policy proposal is to allow the transfer of AS Numbers. This will bring AS Number resources on-par with the other internet resources in terms of the ability to be able to transfer it.

Policy Text

[The following text will update section 3.0 and will create a new section 4.0 in the RIPE Policy Document “Autonomous System (AS) Number Assignment Policies”, if the proposal reaches consensus.]

a. Current policy text

3.0 Returning AS Numbers

If an organisation no longer uses the AS Number, it must be returned to the public pool of AS Numbers. The RIPE NCC can then reassign the AS Number to another organisation.

b. New policy text

AS transfer policy text changes

3.0 Returning AS Numbers

If an organisation no longer uses the AS Number, it should be returned to the public pool of AS Numbers. The RIPE NCC can then reassign the AS Number to another organisation.

4.0 Transferring AS Numbers

Any holder of Autonomous System (AS) Numbers is allowed to re-assign AS Numbers that were previously assigned to them by the RIPE NCC or otherwise through the Regional Internet Registry System.

AS Numbers may only be re-assigned in accordance with the RIPE Policy, “Contractual Requirements for Provider Independent Resource Holders in the RIPE NCC Service Region”.

Re-assignments must be reflected in the RIPE Database. This re-assignment can either be on a permanent or non-permanent basis.

The RIPE NCC will record the change of AS Numbers after the transfer.

The RIPE NCC will publish a separate list of all AS Numbers transferred under this section. The publication shall occur on monthly basis or more frequently if the RIPE NCC so chooses.

The list will contain information about approved and non-approved transfers.

The following information will be published for approved transfers:

• The name of the transferring party
• The name(s) of the receiving party or parties
• The transferred AS Number
• The date each AS Number was transferred

Non-approved transfers will be published in aggregate statistics. In the statistics the following information will be published:

• The Number of requested transfers not approved after the RIPE NCC’s evaluation
• The sum of the AS Numbers included in the requested transfers

Neither the AS Numbers nor the organisations involved will be identified in these statistics.

Please note that the transferring party always remains responsible for the AS Number it receives from the RIPE NCC until the transfer of the resource to another party is completed or if the resource is returned.

Re-assigned AS Numbers are no different from AS Numbers assigned directly by the RIPE NCC and so must be used by the receiving party according to the policies described in this document.

Rationale

a. Arguments supporting the proposal

• The goal of this policy change is to get AS Number resources on-par with other Internet resources in respect to the ability to transfer them.
• Organisations can keep all AS Numbers when consolidating LIRs
• By forcing people to return their already-deployed AS Numbers to the RIPE NCC, it will force companies to either redo their peering or lie to the RIPE NCC to make it look like a merger or acquisition, when it is actually a consolidation between (sister or related) companies.

b. Arguments opposing the proposal

• The RIPE NCC might not be able to return all unused AS Numbers if the resource holder provides valid reasons.

Note: In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication only.

A. RIPE NCC's Understanding of the Proposed Policy

It is the RIPE NCCs understanding that this proposal would allow the transfer of AS Numbers that were previously assigned by the RIPE NCC or otherwise through the Regional Internet Registry (RIR) system, from the rightfully registered resource holder to a new resource holder. 

AS Numbers can only be reassigned if both parties fulfil the contractual requirements for independent resources. 

All AS Number transfers can be on either a permanent or non-permanent basis.

The RIPE NCC would publish a list of all AS Numbers transferred under the policy. Non-approved transfers would be published only in aggregate statistics.

It is the RIPE NCCs understanding that transferred AS Numbers are no different from those assigned directly by the RIPE NCC and so must be used by the receiving party according to the RIPE Document, “Autonomous System (AS) Number Assignment Policies”.

B. Impact of Policy on Registry and Addressing System

Address/Internet Number Resource Consumption:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant impact if this proposal is implemented.

Fragmentation/Aggregation:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant impact if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services:

There are more than 25,500 AS Number assignments eligible for transfer in the RIPE NCC service region. However, because AS Numbers can be requested directly from the RIPE NCC, the amount of transfer requests is expected to be low. This might change once the RIPE NCC’s pool of 16-bit AS Numbers is exhausted.

The RIPE NCC will evaluate the transfer request and will update the RIPE Registry with the AS Number details if it is approved.

Software Engineering:

Software development will be needed to process AS Number transfers. Given the information that is currently available, a medium impact is expected, with around two months needed to develop the necessary software tools.

Billing/Finance Department:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant impact if this proposal is implemented.

RIPE Database:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant impact if this proposal is implemented.

D. Legal Impact of Policy 

If this proposal is implemented, a number of legal documents will need to be updated, including:

• The procedural document “Transfer of Internet Number Resources and Name Changes”
• The transfer agreement template
• The procedural document “Contractual Relationship Changes Between End Users and Sponsoring LIRs”, where any possible implications will be explained
• Template agreement for assignments between End Users and LIRs

Existing contracts between End Users and sponsoring LIRs state that End Users may not transfer their assignments. However, the contracts also state that the use of resources is subject to RIPE Policies which may be amended from time to time. Therefore, if this proposal is accepted, it will be possible to transfer AS Numbers under existing contracts without any changes being required .

E. Implementation

With the information currently available, it is expected that implementation of the proposal would have a medium impact in terms of the software development needed to facilitate AS Number transfers in internal RIPE NCC systems. New processes and documentation will also need to be created. Experience gained from the existing transfer processes for IPv4 PA and IPv4 PI will be used to optimize the implementation process.