Report on the Transfer of the .BJ (Benin) top-level domain to Autorité de Régulation des Communications Electroniques et de la Poste du Bénin (ARCEP BENIN)

7 June 2019

This report is a summary of the materials reviewed as part of the process for the transfer of the .BJ (Benin) top-level domain. It includes details regarding the proposed transfer, evaluation of the documentation pertinent to the request, and actions undertaken in connection with processing the transfer.

Factual Information

Country

The "BJ" ISO 3166-1 code from which the application’s eligibility derives, is designated for use to represent Benin.

Chronology of events

The .BJ top-level domain was initially delegated to the Republic of Benin's Office des Postes et Telecommunications (OPT) in the mid-1990s.

On 5 May 2004, OPT was restructured by Decree 2004-260, resulting in the establishment of Benin Telecoms SA and the transfer of telecommunications-related commercial activities to the new entity. In 2012, this change was assessed to be a governmental restructure and the IANA root zone database was updated to recognize Benin Telecoms SA as the manager of .BJ.

In 2014, the Government of Benin solicited a feasibility study on setting up a new management structure for the .BJ top-level domain, as part of its e-Benin Project. It commissioned Technologies Reseaux & Solutions (TRS), a Togo-based consulting firm composed of specialists in the fields of computer networks and telecommunications, digital economy, law and Internet governance to perform the study. As part of this study, a survey of the Beninese national Internet community was organized. The questions covered a broad range of topics, including the selection of a new management model for the .BJ top-level domain. After analyzing the results of the survey, TRS prepared a feasibility report that recommended transitioning .BJ to a public/private partnership model, with the regulatory authority contracting with a private partner to provide registry services.

On 9 July 2014, Autorité de Régulation des Communications Electroniques et de la Poste du Bénin (ARCEP BENIN), was established by Act 2014-14 on "Electronic Communications and Postal Services in the Republic of Benin" as a regulatory authority. This law was later superseded by Act 2017-20 on the "Digital Code in the Republic of Benin" in 2018.

Articles 209 and 211 of Act 2017-20 state that "the management of domain names, the assignment of all national addressing resources as well as the management of national addressing plan are under the jurisdiction of the regulatory authority" and that "the regulatory authority determines management rules for the domain names".

In March of 2017, ARCEP BENIN initiated a bidding process to select a registry operator for the .BJ top-level domain. After five applications were evaluated, JENY SAS, an Internet Service Provider operating in Benin, was selected and signed an agreement on 14 July 2018 with ARCEP BENIN to provide registry services for the .BJ top-level domain.

Proposed Manager and Contacts

The proposed manager is ARCEP BENIN. It is a governmental regulatory agency based in Benin.

The proposed administrative contact is Hervé Coovi Guedegbe, Executive Secretary of ARCEP BENIN. The administrative contact is understood to be based in Benin.

The proposed technical contact is Donatien Akpo, Technical Manager of JENY SAS.

Evaluation of the Request

String Eligibility

The top-level domain is eligible for transfer as the string for Benin is presently listed in the ISO 3166-1 standard.

Incumbent Consent

The incumbent manager is Benin Telecoms SA. Informed consent for the transfer of .BJ top-level domain to ARCEP BENIN was provided by Médéa César Degbe, General Manager of Benin Telecoms SA and Romain Expédit Houessou, Liquidator of Benin Telecoms SA.

Public Interest

A letter recognizing ARCEP BENIN as the regulator in charge of managing the administrative aspects of the .BJ top-level domain and supporting its selection of JENY SAS to operate the registry was signed by several members of the Benin Internet Community, including:

  • Toundé Dedehouanou, Director of TIC and Studies, Directorate General of Digital Economy and Post, Benin;
  • Kossi Amessinou, Vice-Chairman, Internet Governance Forum Benin;
  • Hospice Alfred Arouna, Networks and Systems Administrator, Isocel Telecom SA, representing Internet service providers;
  • Eric Degboevi, IT Senior Manager, Spacetel Benin SA, representing mobile network operators;
  • Robin Accrombessi, President, La Voix Des Consommateurs, representing a consumers association.

The application is consistent with known applicable laws in Benin. The proposed manager undertakes the responsibility to operate the domain in a fair and equitable manner.

Based In Country

The proposed manager is constituted in Benin. The administrative contact is understood to be a resident of Benin. The registry is to be operated in Benin.

Stability

At the time of request evaluation, the transfer of day-to-day registry operations from Benin Telecoms SA to JENY SAS had already taken place, therefore stability aspects relating to registry transfer have been evaluated on this basis.

The application is not known to be contested.

Competency

The application has provided information on the technical and operational infrastructure and expertise that will be used to operate the domain.

Proposed policies for management of the domain have also been tendered.

Evaluation Procedure

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

A subset of top-level domains are designated for the significantly interested parties 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 to responsible managers that meet a number of public-interest criteria for eligibility. These criteria largely relate to the level of support the manager has from its local Internet community, its capacity to ensure stable operation of the domain, and its applicability under any relevant local laws.

Through the IANA Services performed by PTI, requests are received for delegating new ccTLDs, and transferring or revoking existing ccTLDs. An investigation is performed on the circumstances pertinent to those requests, and, the requests are implemented where they are found to meet the criteria.

Purpose of evaluations

The evaluation of eligibility for ccTLDs, and of evaluating responsible managers 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 transfer ccTLDs, input is sought regarding the proposed new manager, as well as from persons and organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated.

The assessment is focused on the capacity for the proposed manager to meet the following criteria:

  • The domain should be operated within the country, including having its manager 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 manager 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 manager 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 manager to operate the domain; the legal authenticity, status and character of the proposed manager; and the nature of government support for the proposal.

After receiving this documentation and input, it is analyzed in relation to existing root zone management procedures, seeking input from parties both related to as well as independent of the proposed manager 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 manager’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries correctly. Should any anomalies be detected, PTI 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 manager and its suitability to operate the relevant top-level domain.

Document last revised 2019-06-26.