Report on the Redelegation of the .EE domain representing Estonia to Eesti Interneti Sihtasutus

12 May 2013

This report is being provided under the contract for performance of the Internet Assigned Numbers Authority (IANA) function between the United States Government and the Internet Corporation for Assigned Names and Numbers (ICANN). Under that contract, ICANN performs the “IANA functions”, which include receiving delegation and redelegation requests concerning TLDs, investigating the circumstances pertinent to those requests, making its recommendations, and reporting actions undertaken in connection with processing such requests.

Factual Information


The “EE” ISO 3166-1 code is designated for use to represent Estonia.

Chronology of events

The .EE top-level domain was first delegated in the DNS root zone in June 1992. The designated contact person at delegation was Endel Lippmaa of the National Institute of Chemical Physics and Biophysics. The National Institute of Chemical Physics and Biophysics is the currently designated manager for the .EE domain, as described in the IANA Root Zone Database.

In 2007, the Chancellor of Justice of Estonia started a procedure for examining the circumstances related to domain registration and management in Estonia. The Chancellor Of Justice found the legal aspects of registration and management of domain names in Estonia to be “most unclear and persons’ constitutional rights may be prejudiced”. As a result, the Chancellor of Justice asked the Ministry of Economic Affairs and Communications to inform him how the Ministry intends to amend the system of registration of domain names.

On 15 May 2008, the Ministry of Economic Affairs and Communications established a working group to elaborate proposals for reforming the management of the .EE domain. The group included representatives from the Ministry of Economic Affairs and Communications, the Ministry of Education and Research, the Estonian Educational and Research Network (EENet), the National Institute of Chemical Physics and Biophysics (currently listed sponsoring organization) and Jaak Lippmaa (currently listed technical contact). On the basis of the working group’s findings, the Ministry of Economic Affairs and Communications drafted and submitted the concept of improvement of the organization of administration and registration of .EE second-level domain names.

On 13 February 2009, the Eesti Interneti Sihtasutus (Estonian Internet Foundation, or EIF) was founded by the Government of Estonia and the Estonian Association of Information Technology and Telecommunications in order to “manage .EE TLD registry and the .EE primary name server zone”.

On 23 October 2009, EIF made the draft version of the Domain Regulation available to the public and opened a public consultation. 457 proposals were received and deliberated by the Supervisory Board of EIF. The Supervisory Board of EIF approved the Domain Regulation on 21 March 2010.

On 2 July 2010, registration of new domains at the currently designated operator was stopped and the database was imported into the new environment at EIF. EIF began operating the .EE domain on 5 July 2010, without completing a proper redelegation procedure through ICANN.

On 7 November 2012, EIF commenced a request to ICANN for redelegation of the .EE top-level domain.

The current administrative and technical contacts did not agree with the redelegation request at first. However, after holding additional discussions with the Estonian Government, the current administrative and technical contacts agreed to the redelegation of .EE to EIF on 14 December 2012. An additional statement of support was provided by the Chairman of the Board of the NGO Estonian Internet Community, Elver Loho, who had previously voiced his objections in regard to the proposed redelegation.

Proposed Sponsoring Organisation and Contacts

The proposed sponsoring organisation is Eesti Interneti Sihtasutus, a legal person in private law in Estonia.

The proposed administrative contact is Heiki Sibul, Member of the Management Board at Eesti Interneti Sihtasutus. The administrative contact is understood to be based in Estonia.

The proposed technical contact is Hannes Klausen, Member of the Management Board at Eesti Interneti Sihtasutus.

Evaluation of the Request

String Eligibility

The top-level domain is eligible for continued delegation under ICANN policy, as it is the assigned ISO 3166-1 two-letter code representing Estonia.

Public Interest

Support for the application to redelegate the domain was provided by Tonis Lukas, the Minister of Education and Research of Estonia; and Juhan Parts, the Minister of Economic Affairs and Communications of Estonia. Additional statements in support of this redelegation were provided by the Estonian Association of Information Technology and Telecommunications (ITL) and the National Institute of Chemical Physics and Biophysics.

The application is consistent with known applicable local laws in Estonia.

The proposed sponsoring organisation undertakes to operate the domain in a fair and equitable manner.

Based in country

The proposed sponsoring organisation is constituted in Estonia. The proposed administrative contact is understood to be resident in Estonia. The registry is to be operated in the country.


The request is deemed uncontested, with the currently listed sponsoring organisation consenting to the transfer. During the processing of the request, there were objections raised with ICANN, however the parties that had registered objections have since stated they agree with this request to redelegate following dialogue within the country.

A transfer plan has not been provided. As the EIF transferred operations of the domain without performing the redelegation procedure in 2010, approval of this redelegation will not result in a practical transfer of operations that can be properly reviewed for stability concerns.


The application has provided satisfactory details on the technical and operational infrastructure and expertise that will be used to operate the .EE domain. Proposed policies for management of the domain have also been tendered.

Evaluation Procedure

ICANN is tasked with coordinating the Domain Name System root zone as part of a set of functions governed by a contract with the U.S. Government. This includes accepting and evaluating requests for delegation and redelegation of top-level domains.

A subset of top-level domains are designated for the local Internet communities in countries to operate in a way that best suits their local needs. These are known as country-code top-level domains (ccTLDs), and are assigned by ICANN to responsible trustees (known as “Sponsoring Organisations”) that meet a number of public-interest criteria for eligibility. These criteria largely relate to the level of support the trustee has from its local Internet community, its capacity to ensure stable operation of the domain, and its applicability under any relevant local laws.

Through ICANN’s IANA department, requests are received for delegating new ccTLDs, and redelegating or revoking existing ccTLDs. An investigation is performed on the circumstances pertinent to those requests, and, when appropriate, the requests are implemented and a recommendation for delegation or redelegation is made to the U.S. National Telecommunications and Information Administration (NTIA).

Purpose of evaluations

The evaluation of eligibility for ccTLDs, and of evaluating responsible trustees charged with operating them, is guided by a number of principles. The objective of the assessment is that the action enhances the secure and stable operation of the Internet’s unique identifier systems.

In considering requests to delegate or redelegate ccTLDs, input is sought regarding the proposed new Sponsoring Organisation, as well as from persons and organisations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated.

The assessment is focussed on the capacity for the proposed sponsoring organisation to meet the following criteria:

  • The domain should be operated within the country, including having its sponsoring organisation and administrative contact based in the country.
  • The domain should be operated in a way that is fair and equitable to all groups in the local Internet community.
  • Significantly interested parties in the domain should agree that the prospective trustee is the appropriate party to be responsible for the domain, with the desires of the national government taken very seriously.
  • The domain must be operated competently, both technically and operationally. Management of the domain should adhere to relevant technical standards and community best practices.
  • Risks to the stability of the Internet addressing system must be adequately considered and addressed, particularly with regard to how existing identifiers will continue to function.

Method of evaluation

To assess these criteria, information is requested from the applicant regarding the proposed sponsoring organisation and method of operation. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, various documentation is sought describing: the views of the local internet community on the application; the competencies and skills of the trustee to operate the domain; the legal authenticity, status and character of the proposed trustee; and the nature of government support fort he proposal. The view of any current trustee is obtained, and in the event of a redelegation, the transfer plan from the previous sponsoring organisation to the new sponsoring organisation is also assessed with a view to ensuring ongoing stable operation of the domain.

After receiving this documentation and input, it is analysed in relation to existing root zone management procedures, seeking input from parties both related to as well as independent of the proposed sponsoring organisation should the information provided in the original application be deficient. The applicant is given the opportunity to cure any deficiencies before a final assessment is made.

Once all the documentation has been received, various technical checks are performed on the proposed sponsoring organisation’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries correctly. Should any anomalies be detected, ICANN staff will work with the applicant to address the issues.

Assuming all issues are resolved, an assessment is compiled providing all relevant details regarding the proposed sponsoring organisation and its suitability to operate the relevant top-level domain.