Registry Resilience Disaster Recovery and Business Continuity

As the 2026 ICANN New gTLD Program prepares to bring hundreds of new top-level domains into the global internet infrastructure, one of the most mission-critical elements for applicants is demonstrating a credible and technically robust approach to disaster recovery and business continuity. Registry operators are not merely participants in a commercial marketplace—they are stewards of digital trust, responsible for ensuring the availability, stability, and integrity of namespaces upon which countless users, businesses, and institutions depend. In a threat landscape defined by cyberattacks, infrastructure failures, and natural disasters, registry resilience is no longer a theoretical requirement but a mandatory operational standard.

Disaster recovery and business continuity planning (DR/BCP) is a fundamental component of the Registry Services Evaluation and technical review phases of the ICANN application process. To receive delegation, a registry must show that it can maintain critical registry functions in the face of disruptions and that any outage will not compromise the integrity or security of the Domain Name System. These functions include DNS resolution, EPP interfaces for registrar interaction, WHOIS/RDAP services, DNSSEC key management, and escrow compliance. The 2026 round includes updated expectations around DR/BCP planning, emphasizing not just architectural redundancy but also governance, documentation, testing, and real-time responsiveness.

At the core of registry resilience is infrastructure diversity. A registry must operate its services from geographically separate locations that are capable of autonomous operation. For DNS, this means a globally distributed Anycast network that ensures query resolution can continue seamlessly even if a regional node is compromised. EPP and RDAP systems must be deployed in active-active or active-passive configurations with failover capabilities that allow registrar operations to continue without loss of data or transactional consistency. Backend systems, such as database clusters and provisioning interfaces, must be replicated in real-time or near-real-time across multiple data centers, ensuring that service continuity is possible even if the primary facility becomes unavailable.

ICANN requires registry operators to maintain and regularly update a detailed Business Continuity Plan that outlines how critical functions will be restored, prioritized, and communicated during an emergency. This includes specific Recovery Time Objectives (RTO) and Recovery Point Objectives (RPO) for each registry function. For example, the RTO for DNS resolution might be near-zero, while the RPO for EPP transactions could be within minutes. Operators must demonstrate that they can meet these objectives through a combination of infrastructure, automation, human oversight, and contractual agreements with service providers. The plan must also define the roles and responsibilities of response teams, escalation pathways, internal and external communication plans, and methods of continuous monitoring during an incident.

Data protection is another central pillar of DR/BCP. Registries are required to comply with ICANN’s data escrow requirements, which mandate daily deposits of registration data to an approved escrow agent. In the event of a registry failure, ICANN or an Emergency Back-End Registry Operator (EBERO) can access this data to resume registry operations. The escrow process must be automated, securely encrypted, and verified through checksums and integrity validations. For business continuity, registries must also implement internal backup systems that capture not only domain data but also zone files, DNSSEC keys, logging data, configuration states, and system images. These backups must be isolated, tested regularly, and stored in multiple secure physical or cloud locations.

The role of EBERO has been expanded in the 2026 program, reflecting the growing complexity of TLD services and the potential impact of extended outages. ICANN maintains relationships with EBERO providers who can step in if a registry is unable to maintain core services. As part of DR/BCP planning, registries must coordinate with ICANN and their chosen backend provider to define clear handover protocols, including access controls, data decryption procedures, and transition timeframes. Registries must also engage in periodic drills or tabletop exercises involving EBERO scenarios to prove operational readiness.

Testing is a requirement that has been significantly reinforced in the latest ICANN guidelines. It is no longer sufficient to maintain a static DR/BCP document—registries must conduct real-world testing of their plans, document the outcomes, address deficiencies, and update protocols accordingly. These tests may include simulated data center failures, loss of DNS nodes, registrar-side connectivity disruptions, or cyber incident scenarios. The results must be auditable and available for ICANN review. Registries are also encouraged to integrate business continuity testing into their regular SLA monitoring and incident management processes, creating a feedback loop that improves preparedness over time.

Cybersecurity incident response is now tightly integrated with DR/BCP planning. Registries are required to maintain a security incident response plan (SIRP) that coordinates with business continuity protocols. This includes threat detection capabilities, isolation procedures, malware containment, and coordination with law enforcement or national cyber defense authorities if necessary. In the event of a targeted attack such as DNS hijacking or a ransomware campaign against registrar systems, the registry must have predefined paths for service isolation, secure recovery, and restoration of data from uncompromised sources. This aspect of DR/BCP planning must be consistent with ICANN’s contractual obligations as well as global regulatory frameworks such as the NIS2 Directive and GDPR.

Communication during an incident is as important as technical recovery. Registries must be able to notify ICANN, registrars, and in some cases registrants within specific timeframes following a disruption. This includes disclosing the nature of the incident, the services affected, expected restoration timelines, and interim mitigation measures. In the 2026 round, ICANN places heightened emphasis on transparency and stakeholder coordination, requiring registries to document their communication templates, channels, and escalation policies. Maintaining trust during an outage depends on timely, accurate, and well-managed communications.

For smaller or community-based applicants, achieving full registry resilience may seem daunting, but ICANN allows the use of outsourced providers, provided that contractual controls, audit rights, and performance SLAs are in place. These applicants must ensure that their backend service providers can deliver against all DR/BCP criteria and that they maintain operational transparency. The responsibility for compliance ultimately rests with the registry operator, and applicants must demonstrate oversight capacity and internal coordination, even if infrastructure is externally managed.

In a world increasingly shaped by geopolitical instability, environmental disruption, and sophisticated cyber threats, registry resilience has become a baseline expectation for participation in the domain name ecosystem. ICANN’s evolving standards reflect not just a technical mandate but a governance imperative—ensuring that no single point of failure can disrupt global internet operations. For 2026 applicants, disaster recovery and business continuity planning must be integrated into the fabric of registry design, supported by modern infrastructure, tested policies, and a culture of operational excellence. Those that take resilience seriously will not only meet ICANN’s requirements but will also earn the confidence of registrars, registrants, and the broader internet community.

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As the 2026 ICANN New gTLD Program prepares to bring hundreds of new top-level domains into the global internet infrastructure, one of the most mission-critical elements for applicants is demonstrating a credible and technically robust approach to disaster recovery and business continuity. Registry operators are not merely participants in a commercial marketplace—they are stewards of…