The European NIS/2 Directive is set to take effect on October 17, and its implications, particularly “Article 28,” are causing alarm across the domain registration landscape. The changes outlined in the directive will have a significant impact on domain name registrations. However, most EU countries are still unprepared, with no clear regulations ready for implementation. Also in Belgium, while a legal framework is in place (unlike in some other nations) there remains considerable uncertainty.
Based on our conversations with BIPT and other stakeholders, it looks like Belgian legislators and regulators will be taking an extra stringent approach, aiming to go beyond the minimum requirements imposed by NIS/2. This has raised concerns, particularly regarding the competitive position of Belgian registrars. Discussions with the Belgian Institute for Postal Services and Telecommunications (BIPT) on this issue are ongoing.
Meanwhile, it appears that Belgian registries are scrambling in a last-minute effort to update their systems in preparation for the October 17 deadline. They seem to be engaging in a form of “panic football,” rushing to make adjustments they believe are necessary to comply with NIS/2.
Note: we’ve just been informed by DNS Belgium that, based on our contact with them, the below new requirements have been postponed until after they’ve been further discussed with registrars.
For the .be domain, the most notable change is the upcoming requirement for companies to provide a VAT number. Typically, DNS Belgium is known for involving registrars in the planning and implementation of technical changes. However, in this case, there was no consultation, and communication surrounding the change was also lacking. Although DNS Belgium first communicated this update in early July, none of the registrars we spoke with had noticed it. Even the lone reminder sent out by DNS Belgium went largely unnoticed, leaving many registrars only recently aware of the upcoming change due to our outreach efforts.
While many registrars find it relatively easy to support a VAT number field in their systems, there is growing concern about the tight timeframe for engaging resellers. Additionally, standard control panels frequently used for domain management, such as WHMCS or HostFact, may require more time to implement these changes. There is also no solution yet for companies or organizations that wish to be the registered owner of a .be domain but are not subject to VAT. In many countries, company registration numbers do not follow the same structure as VAT numbers, meaning their registrations may be rejected.
As of today, September 12, EURid has announced that they too will be adjusting their procedures. They will no longer allow transfers of blocked domain names. We reached out to them to obtain more details about this and have received confirmation that this would not influence a transfer out of quarantine, but is only intended to prevent a transfer of a .eu domain name that was blocked due to compliance issues. Furthermore, more changes are expected, though details have not yet been provided.
Neither EURid nor DNS Belgium involved registrars in these adjustments, and questions remain about the necessity of some of these changes, particularly given the tight deadline. We are actively seeking dialogue with both EURid and DNS Belgium regarding these issues. Meanwhile, we are also in talks with the BIPT, in collaboration with FeWeb and supported by organizations such as Agoria, BeCommerce, Comeos, and ISPA, to mitigate the impact on the competitive position of Belgian registrars.
The lack of clear communication, combined with the pressure of imminent changes, has led to an environment of uncertainty and concern within the Belgian domain registration industry.