Dear Cynthia, all

Thank you for your feedback and for highlighting the challenges our Registry teams face when verifying members and independent resource holders worldwide.

The distinguishing between legal entities and natural persons is an essential guiding principle. Partnerships are indeed complex, as their legal status differs between countries (and sometimes even within). I took a quick look at the theoretical Swedish example you mentioned but could not find an real example among current resource holders. If you are aware of a real case, please send it to me directly by email. To keep this thread focused on the proposal, I would prefer not to continue the broader discussion on partnerships here. However, if you believe the RIPE NCC’s understanding of the legal status of your specific partnership should be reviewed, please feel free to contact me directly.

To reiterate: if this proposal will be accepted, the RIPE NCC would publish registration numbers only for legal entities. Sole proprietorships would therefore not have a number published, even if they appear in some countries in national business registries.

You are also correct that some countries assign multiple identification numbers. Our Registry teams have built quite some experience in determining which number is most appropriate to record. If this proposal is accepted, the implementation will include a review of existing data to ensure consistency and completeness, particularly for countries that have multiple business registries. Thank you to everyone who shared suggestions on this topic, including ideas about publishing supporting information on registration numbers. We will take these into account when assessing feasibility and implementation effort.

Kind regards,
Marco Schmidt
RIPE NCC

On 21/11/2025 11:45, Cynthia Revström wrote:
Hi Marco and WG,

I am mostly neutral on this proposal, seems like a reasonable thing to
do but doubt it changes the situation that much.

However I do have some concerns, primarily around the classification
of entities and numbers.

This change makes it even more important that the NCC correctly
classifies entities and their associated registration numbers.
I have seen how the NCC has struggled with this, especially in cases
that differ depending on jurisdiction.

As an example: in Sweden, partnerships (Handelsbolag) and limited
partnerships (Kommanditbolag) are both legal entities, separate from
the people or entities behind them.
Despite this, I have seen Swedish entities being registered as "John
Doe trading as Acme Networking Kommanditbolag" despite that being a
legal entity with an organisation number.
Meanwhile sole proprietorships in Sweden aren't legal entities so
instead they are registered with the person's ID number.
On top of this, Swedish personal ID numbers and organisation numbers
have the same format.
For these reasons I don't currently trust that the NCC would publish
the number for the partnership but not for the sole proprietor.

I assume there are more cases like this in other countries, so I would
like the NCC to look through their data and make sure that they have
correctly classified entities before they publish their numbers.
If there is a list at the NCC with which kinds of organisations are
considered legal entities (and possibly which registry registers them)
in different countries then I think it would be good if that could be
published.

My other concern was with organisations having multiple different
identification numbers and making sure to publish the correct one.
For example: in the US, most (all?) companies have an EIN with the IRS
for federal taxes, this number is distinct to the actual company
registration number that they might have at the state level which is
the one that should actually be published.
This case is possibly rather obvious but I wouldn't be surprised if
there are more cases like this in other jurisdictions that are not as
obvious and that the NCC hasn't caught yet.
Here I would also like to see a list with which numbers are used for
which kinds of entities if there is such a list (and if not then I
think that there probably should be such a list).

-Cynthia

On Mon, Nov 17, 2025 at 12:01 PM Marco Schmidt <[email protected]> wrote:
Dear colleagues,

Following my presentation at the RIPE 91 Address Policy Working Group
session, I’d like to propose adding a company registration number to the
organisation object type.

Problem Statement:
The RIPE Database should allow users to uniquely identify Internet
Number Resource holders. Today, organisation objects linked to RIPE NCC
co-maintained inetnum, inet6num, and aut-num objects include the
validated legal organisation name and country code where the resource
holder is legally registered. However, these attributes alone are not
always sufficient to uniquely identify a legal entity, for three main
reasons:

1. Identical names: In some jurisdictions, different companies can
legally register with the same or very similar names.
2. Transliteration issues: In countries using non-Latin scripts,
converting names from and into Latin characters can produce inconsistent
or inaccurate results.
3. Data discrepancies: Differences between the validated legal
information (org-name and country) and the contact details maintained by
the resource holder (for example, a postal address in another country)
can create confusion and make identification more difficult.


Solution Definition:
Introduce a new reg-nr: attribute for RIPE NCC co-maintained
organisation objects, containing verified company registration numbers
issued by national authorities. The RIPE NCC already holds this
information for ~99% of resource holders that are legal entities.

Publishing a unique and verifiable registration number will
significantly improve the ability of RIPE Database users to accurately
identify resource holders and cross-check them in national company
registries.

Only publicly available registration numbers of legal entities will be
published. Natural persons remain explicitly out of scope.


Please let me know your feedback. Questions and comments are welcome.

Regards
Marco Schmidt
Manager Registration Services
RIPE NCC

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