Evolving Role of the GAC From Advice to Oversight

The Governmental Advisory Committee (GAC) within the ICANN multistakeholder model has undergone a marked transformation since its establishment in the late 1990s. Originally envisioned as a forum through which national governments and intergovernmental organizations could offer non-binding public policy advice to the ICANN Board, the GAC’s influence has steadily expanded in both scope and impact. While its formal role remains advisory, in practice the GAC has moved into a position that increasingly resembles that of an oversight body—exerting growing influence over the policy development process, operational decisions, and global norms surrounding the governance of top-level domains (TLDs).

The GAC’s influence stems from its composition and its proximity to national sovereignty. It is composed of representatives from over 170 countries, territories, and organizations, including powerful geopolitical actors such as the United States, the European Union, China, and Russia. Although its advice is non-binding under ICANN’s Bylaws, the Board is required to consider GAC consensus advice and must either accept it or provide a clear rationale for rejection. This requirement has effectively elevated the GAC’s standing above that of other advisory committees and even sometimes above consensus positions of the Generic Names Supporting Organization (GNSO), which is the body primarily responsible for developing gTLD policy.

One of the earliest and clearest demonstrations of the GAC’s assertive role came during the rollout of the New gTLD Program. Governments raised concerns about certain strings they deemed sensitive—such as names of geographical significance, religious terms, and words associated with regulated sectors like finance or health. In response, the GAC issued a list of strings subject to “safeguards,” leading ICANN to impose additional requirements on applicants for TLDs like .bank, .doctor, and .insurance. While technically framed as advice, these safeguard recommendations carried de facto authority. Most applicants complied or adjusted their proposals to avoid objections, fearing rejection or delays in the evaluation process. This established a precedent in which the GAC’s determinations effectively shaped operational outcomes and policy implementation, even though the underlying policy development had not originated through the usual bottom-up processes.

Further evidence of the GAC’s expanded role emerged in its involvement with public interest commitments (PICs). Although the PIC mechanism was introduced by ICANN to manage TLD-specific contractual obligations, many of the PICs were heavily influenced or directly proposed in response to GAC input. This demonstrated a subtle shift: rather than advising on general policy, the GAC began to directly influence the contractual landscape between ICANN and registry operators. Its role thus extended beyond advice into quasi-regulatory function, determining how certain domains could or could not be operated.

The IANA stewardship transition in 2016, which saw the U.S. government formally relinquish its legacy oversight of the DNS root zone, further elevated the importance of the GAC. As ICANN shifted toward a more globalized governance model, the question of government legitimacy within that system became more pronounced. To assuage concerns from states wary of private-sector dominance, the post-transition accountability framework preserved and reinforced the GAC’s unique position. The GAC was explicitly acknowledged as a participant in the Empowered Community, the mechanism through which the ICANN community can hold the Board accountable. Although the GAC chose not to exercise voting power within this framework to avoid potential conflicts of interest, its mere presence as a standing member reflects a deeper integration into oversight mechanisms that go beyond simple advisory input.

At the same time, the GAC has taken a more structured approach to internal governance, coordination, and intersessional work. Its communiqués, once brief and loosely structured, are now lengthy, detailed documents that influence the timing and framing of key ICANN decisions. The GAC maintains regular interactions with the Board, the GNSO, and other supporting organizations, and its positions are often shaped through cross-ministerial collaboration, giving its advice a national-policy weight that no other stakeholder group can match. This evolution has led to greater sophistication in its deliberations but also to criticism that its increased involvement can undermine the bottom-up, consensus-driven ethos of the ICANN model.

Critics of the GAC’s growing influence caution that its actions, though procedurally couched in “advice,” can override years of work by community policy bodies. There is concern that the informal yet impactful nature of GAC interventions creates an asymmetric power dynamic where governments can effectively veto or modify outcomes late in the policy development lifecycle, without participating fully in the deliberative process. The lack of transparency in some GAC decision-making, especially when advice is based on opaque national interests or closed-door consultations, has prompted calls for the GAC to adopt greater procedural openness and accountability consistent with ICANN’s multistakeholder norms.

Proponents of the GAC’s assertive role, however, argue that governments have a unique responsibility to safeguard the public interest, particularly in areas involving consumer protection, national security, and cultural sensitivity. They contend that without a strong GAC, ICANN could drift into purely commercial or technocratic decision-making, insufficiently grounded in public policy considerations. As the internet becomes ever more central to societal functions, the role of governments—through the GAC—must evolve accordingly to ensure that ICANN remains a legitimate and responsive global institution.

Looking ahead, the GAC’s evolution from advice-giver to oversight actor raises important questions about balance and legitimacy within ICANN’s governance system. Can a model originally designed to insulate technical decision-making from political interference adapt to a world in which political considerations are inseparable from DNS governance? What mechanisms can ensure that GAC advice, especially when it carries operational consequences, is subject to the same transparency and accountability expectations as other forms of policy input? And how can ICANN ensure that other stakeholders retain meaningful influence if governmental perspectives increasingly dominate high-stakes decisions?

The answers to these questions will shape the next phase of ICANN’s development. As the GAC continues to assert itself on issues ranging from TLD application reviews to human rights to DNS abuse mitigation, it will need to reconcile its growing power with the collaborative, inclusive spirit that defines the ICANN model. Likewise, the broader ICANN community must recognize the GAC’s evolution not as a threat but as an opportunity to institutionalize more robust checks, balances, and dialogue across stakeholder boundaries. In doing so, ICANN can ensure that its unique model of internet governance remains both resilient and legitimate in the face of a complex and changing global environment.

The Governmental Advisory Committee (GAC) within the ICANN multistakeholder model has undergone a marked transformation since its establishment in the late 1990s. Originally envisioned as a forum through which national governments and intergovernmental organizations could offer non-binding public policy advice to the ICANN Board, the GAC’s influence has steadily expanded in both scope and impact.…