ESG Scoring and the Next gTLD Round: Sustainability Clauses to Watch

As the global focus on Environmental, Social, and Governance (ESG) standards continues to intensify, the next round of new gTLD applications from ICANN is poised to reflect this paradigm shift. While the 2012 round of applications emphasized technical stability, legal rights, and string similarity, the landscape today is increasingly shaped by digital responsibility, ethical governance, and environmental sustainability. Stakeholders ranging from regulators and investors to civil society are now pressing for higher transparency and accountability, making ESG considerations not just a reputational issue but a strategic one for gTLD applicants. Understanding how ESG metrics could be embedded in application reviews, registry operations, and contractual obligations will be critical for both traditional registry operators and new market entrants.

Environmental responsibility is gaining prominence in the internet infrastructure space. While domain name operations are inherently digital, their supporting infrastructure—including data centers, DNS services, and registry backend systems—consume significant energy. ICANN has not historically included sustainability metrics in its evaluation of gTLD applications, but the growing push from governments and NGOs to green the internet could introduce new sustainability clauses in the Applicant Guidebook. These clauses may require operators to disclose their energy usage, detail their reliance on renewable energy, and describe carbon mitigation strategies. Some countries or regions may push for language mandating climate disclosures as part of registry service provider contracts, especially if the backend operator manages hundreds of gTLDs. Applicants should begin preparing for the possibility that demonstrating a low-carbon footprint and green DNS infrastructure will be viewed as a competitive advantage in the evaluation process or even a mandatory compliance criterion in certain jurisdictions.

Social impact considerations are also expected to take a more prominent role in the evaluation and stewardship of future gTLDs. In the prior round, community-based applications were given special consideration, but this time the scope may widen to include broader social accountability. This could mean applicants must show how their proposed gTLD contributes positively to the digital ecosystem—whether by improving digital inclusion, promoting human rights, or ensuring accessibility for marginalized populations. Registries might be asked to outline policies for combating online abuse, misinformation, and hate speech, not merely as terms of service but as enforceable obligations backed by transparent reporting mechanisms. Additionally, the treatment of user data—particularly in light of GDPR and other emerging privacy frameworks—may fall under the social pillar of ESG. Applicants that can demonstrate robust privacy protections, ethical data handling, and user consent protocols will likely be more favorably received, especially if they propose open or widely adopted strings.

Governance, the third pillar of ESG, will be under closer scrutiny than ever before. ICANN’s own accountability mechanisms have evolved since 2012, and they are increasingly shaped by stakeholder demands for transparency and fairness. Applicants in the next round can expect more rigorous expectations around internal governance, conflict of interest disclosures, and operational transparency. Registries may be required to provide evidence of stakeholder engagement, particularly for TLDs that represent geographic regions, cultures, or sensitive sectors. Governance practices related to domain allocation policies, premium name auctions, and reserved name lists could be assessed for fairness and equity, particularly if the gTLD targets a public interest area such as health, finance, or education. The ability to demonstrate inclusive policy development processes—such as public consultation or advisory committees—may bolster an applicant’s score or reduce the risk of objections.

Some observers have speculated that ICANN may introduce an ESG disclosure requirement into the application itself, either as a standalone section or embedded within existing evaluation criteria. Such a requirement would compel applicants to articulate their ESG commitments in measurable terms, possibly with third-party verification or self-assessment scoring frameworks. Frameworks such as the Global Reporting Initiative (GRI), SASB, or ISO 26000 could serve as models for such disclosures, particularly if ICANN seeks consistency and comparability across applicants. While this may initially seem burdensome to smaller entities, it would elevate the overall integrity of the gTLD ecosystem and align it more closely with global digital governance trends.

Investors and corporate applicants are already moving in this direction. For brand TLDs, where companies use gTLDs for internal or marketing purposes (such as .brand), ESG alignment may be part of broader corporate sustainability goals. These applicants may voluntarily integrate ESG principles into their registry policies to align with shareholder expectations and sustainability indices. Similarly, public interest TLDs operated by NGOs or coalitions may use ESG commitments as a way to differentiate themselves and attract community support. In this context, failure to engage meaningfully with ESG considerations could become a strategic liability, both in ICANN’s evaluation and in long-term stakeholder engagement.

Moreover, geopolitical trends cannot be ignored. The United Nations and several regional digital policy bodies have emphasized sustainability in digital development. If ICANN’s next gTLD round coincides with increasing regulation from bodies like the EU or national governments, it is plausible that policy pressure could result in ESG-mandated contract clauses. Such clauses might include requirements for diversity in registry leadership, non-discriminatory access provisions, or environmental impact assessments of infrastructure providers.

Preparing for these possibilities means future gTLD applicants should begin ESG integration early. This includes conducting ESG materiality assessments, selecting environmentally responsible registry service providers, and developing policies that address both the social and governance dimensions of their operations. Legal teams may need to revisit standard registry agreements to incorporate ESG clauses, and financial planners should anticipate potential compliance costs related to audits, disclosures, or third-party certifications.

The next gTLD round will not only be a test of innovation and market positioning but also a measure of how effectively applicants can align their digital ambitions with the ethical, environmental, and governance expectations of a rapidly evolving global internet community. Those who treat ESG as central rather than peripheral will be better positioned to meet the regulatory challenges ahead and to earn the trust of users, regulators, and the broader ICANN ecosystem.

As the global focus on Environmental, Social, and Governance (ESG) standards continues to intensify, the next round of new gTLD applications from ICANN is poised to reflect this paradigm shift. While the 2012 round of applications emphasized technical stability, legal rights, and string similarity, the landscape today is increasingly shaped by digital responsibility, ethical governance,…