A few thoughts on Dot EU and Brexit

Here’s a summary of my advice on LinkedIn regarding the Dot EU domain and Brexit.

With the Brexit negotiations in the media, it’s worth reviewing your domain registrations for Dot EU domains, particularly considering the EU Technical Notices. It’s worthwhile scoping out a plan and BC to ensure continued services in Q1 2019 and beyond.

One potential outcome of the Brexit process is losing registration, which might (depending on how integrated the domain is to the company lead to a permanent loss of service). Companies should put (board level) risk management plans in place for this issue as necessary now.

As written, the EU Technical Notice for this topic  states the EU Registry will be entitled to revoke any Dot EU domain at the withdrawal point, without any opportunity for appeal.

The worst-case scenario is any Dot EU domain will be revoked on exit day in March 2019, with loss of linked services. Hopefully this will not arise, but the impact would be significant – about 300,000 domains are registered under Dot EU to UK registrants.

Personally, I believe they will probably allow registrations to continue the full term and then lapse, but this assumption cannot be relied upon. In addition, for many businesses, relying on natural lapse processes may not be that helpful – they may be relatively short anyway, perhaps working with 12- or 24-month automatic renewal periods. Grandfathering processes can be hoped for, but not relied on.

A sensible approach is to assume Dot EU registrations will be cancelled in March 2019, and start planning now, until either the EU or the registries provide more clarity.

One option, which I am aware some companies are doing, is migrating to what they perceive to be is a more reliable domain (e.g. .NET, .COM, .UK). This process can take a lot longer than one might assume, particularly if complex services are integrated into the domain name.

Another option is to put in place a fairly static site that you can switch to in case of service interruption.

For EU citizens the position may be different owing to the EU making proposals in April this year to open Dot EU registration to any EU citizen regardless of country – though these have yet to be put into action as I understand and it’s unclear how this would apply to companies.

Of course, the picture may change once the terms of the Brexit arrangements are made public. But sensible risk management can get underway now.

Other things to consider in your risk planning:

  • Are you reliant on SaaS services that use Dot EU domains?
  • Is your cyber supply chain based on Dot EU domains?
  • Are your sales, e.g. resellers, reliant on Dot EU domain services?
  • Your site may be indexed on numerous search engines, and it will take time for any new site to be picked up satisfactorily (plan ahead).
  • Customers may take time to update email addresses, e.g. for customer service or support.

For the above make enquiries now to ensure continuity of service, or so mitigation can be put in place.