Yesterday I sent a submission to auDA's Policy Advisory Panel in response to the ".au Licensing Rules Review 2025: Draft Report". I don't usually do policy posts, but after roughly 20 years working in IT, hosting and domains in Australia, helping registrants of every size through registration, renewal, transfer, expiry and the occasional painful recovery, I have some fairly strong opinions about how the .au namespace should work. So I wrote them down and sent them in.
Read the full submission (PDF)
For the record: I have no commercial interest in domain trading. My interest is the boring one, keeping the namespace useful for the businesses and people it exists to serve.
The allocation rule is the whole ballgame
The part of the Draft Report that matters most is Recommendation 2, which deals with the allocation rules for com.au and net.au. The Panel put up three options, and I backed the strongest one, Option 3: delete subparagraph 2.4.4(2)(f) of the .au Licensing Rules entirely.
That subparagraph is the mechanism by which large-scale speculative registration gets legitimised. Under it, almost any domain can be justified after the fact as being "used for a service", where the service turns out to be domain parking, pay-per-click ads, or simply offering the name itself for sale or lease. As I put it in the submission: "A rule that can be satisfied by the act of holding the domain is not, in practice, an allocation rule at all."
The other two options don't fix that. Option 1 is more compliance activity, but auditing against a rule that permits the conduct just confirms the conduct is permitted. Option 2 clarifies the definition of "Services", which in my experience invites reframing rather than behaviour change: portfolios get re-described to fit whatever wording survives. Only deleting (f) removes the ambiguity at the source. Allocation should mean a genuine connection between the registrant and the name.
Marketplace and monetisation operators will say removal hurts them financially, and they're right, it would. But those business models exist because a permissive provision made them possible. The question for the Panel is whether the provision serves the purpose of the namespace, not whether businesses have come to depend on it. A public-interest namespace should not be protecting revenue from warehousing names that genuine Australian businesses would actually use.
This isn't abstract. A meaningful share of the attractive natural-language com.au inventory sits with a small number of portfolio operators, and small businesses get a choice between paying secondary-market prices or settling for a lesser name. I've got skin in this one too: an exact-match family-name domain I have long had genuine use for has been held for years by an unrelated party with no apparent connection to the name.
If the Panel won't adopt Option 3, my fallback was to treat Option 2 as a floor rather than a ceiling: expressly exclude parking, PPC landing pages and for-sale or lease listings from ever constituting a "service", with Option 1's compliance checks layered on top. And on Recommendation 1 (monetisation), I don't support "no change". Audits address symptoms, not the setting that produces them. Recommendations 1 and 2 have to be considered together.
Lifecycle and renewals: the unglamorous stuff that bites people
I also gave strong support to Recommendations 6 and 8, on the licence lifecycle and renewal communications. After two decades of helping people recover domains, I can tell you most lapsed domains lapse for mundane reasons: an expired credit card, notices going to a stale mailbox or a staff member who left, a hosting provider that mishandles the renewal, or simple oversight.
Then the name drops, gets caught within seconds by automated drop-catchers, gets monetised or listed, and is offered back at many multiples of the registration fee. "The original registrant's administrative slip becomes another party's leverage."
So I supported mandatory multi-channel renewal notices (email plus SMS where available) starting well before expiry, plain-language notices that state the final recovery date and cost, and the standardised 30-day redemption period with a 5-day pending or hold period.
The bottom line
.au is a public resource administered in trust for the Australian community, and the central question in this review is the allocation rule. My ask of the Panel is simple: adopt Option 3, and weigh the long-term integrity and fairness of com.au and net.au above business models built on the current rule's breadth.