AFRINIC – the RIR overview and main terms IP subnets owners should know

The AFRINIC history

AFRINIC (African Network Information Center) is the Regional Internet Registry (RIR) responsible for allocating and managing IP addresses and autonomous system numbers for the African continent. AFRINIC was officially established on April 22, 2004, in Mauritius. It was created to serve as the Regional Internet Registry (RIR) responsible for managing and allocating Internet Number Resources (IP addresses and autonomous system numbers) for the African continent. Like other RIRs, AFRINIC faced the challenge of IPv4 address exhaustion as the demand for internet connectivity increased in Africa. As of July, 2023 their pool of available IPv4 addresses has only 1x/12 IPv4 subnet.

AFRINIC is the only one RIR that still doesn’t support Inter-RIR transfers, The lack of necessary policies is connected to a profound crisis that AFRINIC has been experiencing since 2021 due to legal disputes with Cloud Innovation Ltd. As a result of these disputes, AFRINIC’s accounts have been frozen, and the organization’s operational activities have been partially restricted by court of Mauritius.

The AFRINIC Crisis:

According to official AFRINIC version published on their website, in June 2020, AFFRINIC detected violations of their service agreement made by one of its members, Cloud Innovation Ltd. AFRINIC asked to explain the breach and remedy it. In March, 2021 AFRINIC announced the since the breaches of the Registration Service Agreement (RSA) remain, AFRINIC initiated the deregistration of 6.2 million IPv4 addresses allocated earlier by AFRINIC to Cloud Innovation Ltd. Cloud Innovation didn’t agree with decision made by AFRINIC and initiated the first lawsuit against them before the Supreme Court of Mauritius. The Court rejected Cloud Innovation’s first application July 7, 2021, following which AFRINIC terminated Cloud Innovation’s resource membership giving them a 90 days’ notice before deregistering the allocated IP addresses.

In July, 2021 AFRINIC received a Notice of Appeal challenging the judgment from July 7, 2021, along with an additional Interim Order that prohibits the termination of Cloud Innovation’s RSA (Registration Services Agreement). A bit later, Cloud Innovation also submitted an application and successfully obtained a Provisional Authorization to Attach Order, commonly referred to as a Freezing Order. This order has been granted with the intention of freezing all amounts, both separately and jointly, up to USD 50 Million held by SBM (Mauritius) Ltd and Mauritius Commercial Bank Ltd. On July 13. AFRINIC’s bank accounts were frozen.

In November 4, 2022 the contract with the CEO of AFRINIC Eddy Kayihura’ expired. Due to the complexities arising from decisions in Mauritian courts, AFRINIC faces challenges in forming a properly constituted Board of Directors, preventing the organization from conducting an election to address the situation. Consequently, there is no existing authority that could have renewed Eddy’s employment contract with AFRINIC. Such renewal could only be carried out through a Board resolution.

As of today, there’re over 25 lawsuits initiated by Cloud Innovation or other affiliated companies against AFRINIC.

Main documents:

AFRINIC has several main policies that govern the allocation and management of Internet number resources (IPv4, IPv6, and ASNs) within the African region. These policies are developed and maintained through a community-driven process and are subject to updates and revisions as needed. Some of the main policies include:

IPv4 Subnet types

• ALLOCATED PA – This designation is assigned to IP resources provided by AFRINIC to its LIR (Local Internet Registry) Resource members. These prefixes are intended for use on the LIR’s infrastructure and for their customers (End-Users).
• ALLOCATED UNSPECIFIED – AFRINIC uses this status for placeholder records, such as 41.0.0.0/8, to indicate resources where specific details have not been specified.
• SUB-ALLOCATED PA – This status is granted to IP address prefixes that have been sub-allocated by an LIR to its customer, often another ISP (Internet Service Provider), with the intention of further distribution to the ISP’s own customers.
• ASSIGNED PA – IP addresses with this status are registered as being assigned by an LIR to its infrastructure and customers.
• ASSIGNED PI – This status is given to IP resources issued by AFRINIC to its Resource members (also known as End Sites) for use on their individual infrastructures.
• ASSIGNED ANYCAST – Resources receiving this status are issued under the Assigned Anycast policy, typically utilized for anycast addressing.
• POLICY-RESERVED – This status is applied to resources that AFRINIC must reserve to comply with ratified policies, such as 196.60.0.0/16, ensuring their adherence to the specified policies.

IPv4 transfer terms

• IPv4 resources eligible for transfer must originate either from an active AFRINIC member’s account or from a Legacy Resource Holder located within the AFRINIC service region.
• The source of the IPv4 address resources for transfer must be the current rights holder as officially recognized by AFRINIC. Additionally, the source must not be involved in any dispute regarding the status of those resources. This ensures that the IPv4 transfer process is conducted with proper authorization and that there are no unresolved conflicts or disputes regarding the ownership of the IPv4 address resources.
• Source entities that have their IPv4 address transfer approved will be ineligible to receive any further IPv4 address allocations or assignments from AFRINIC for a duration of 12 months following the transfer approval.
• Before the transfer request approval, the source entities must not have received any transfer, allocation, or assignment of IPv4 number resources from AFRINIC within the preceding 12 months. However, this restriction does not apply to transfers resulting from mergers and acquisitions.
• The recipient’s need for the IPv4 number resources must be approved by AFRINIC. To qualify for receiving a transfer, an organization must justify its IPv4 resource needs and demonstrate compliance with the prevailing AFRINIC policies. This involves justifying and demonstrating the usage of their initial/additional allocation/assignment, as applicable, based on the current policies in effect.
• The recipient must be an AFRINIC member and must adhere to the existing AFRINIC policies. Additionally, the recipient must sign the Registration Services Agreement for the resources they are receiving.
• Any IPv4 legacy resources that are transferred will no longer be considered as legacy resources after the transfer. They will now be governed by AFRINIC’s standard resource management policies.

LIR registration overview

Any organization in need of services from AFRINIC is eligible to apply for membership. However, AFRINIC can only accept membership applications from organizations that have a registered legal entity located within the AFRINIC service region.

While there are no specific qualifying criteria to become a member of AFRINIC, it’s important to note that membership does not automatically guarantee the receipt of an IP address allocation. The allocation of IP addresses is subject to separate evaluation and adherence to AFRINIC’s policies and guidelines. Membership and address allocation are distinct processes, and meeting the requirements for membership does not guarantee immediate IP address allocation.

Documents and information required for LIR registration in AFRINIC:

AFRINIC is authorized to provide services solely to organizations that function as legal entities within the AFRINIC service region. As part of the process, along with “The AFRINIC Service Agreement,” AFRINIC may request a copy of your organization’s registration with the local Chamber of Commerce or its equivalent.

It is crucial to note that AFRINIC will only accept a duly signed copy of “The Service Agreement” in the English language as part of the membership and service provision requirements.

AFRINIC will additionally require administrative details about the new Local Internet Registry (LIR), including address and telephone numbers, names of contact persons, and billing information. If your billing address is in Mauritius, please provide your VAT number as well. These details must be filled in the AFRINIC Services Agreement, which will serve as the official contract between the LIR and AFRINIC upon signing.

IPv4 allocation terms

First Allocation requirements:

a) AFRINIC’s initial allocation will be a minimum of /22 or 1024 IPv4 addresses.

b) The organization must be an active AFRINIC member in good standing, and

c) The applicant must demonstrate efficient utilization of IP addresses from their upstream provider. The justification for the allocation can be based on an immediate need, taking into account existing usage. In such cases, the existing assignments must be renumbered into the LIR’s new allocation.

Verification of previous efficient utilization is based on assignments (and sub-allocations) registered in the RIPE, ARIN, LACNIC, and APNIC databases. Only these registered assignments will be considered valid for the purpose of evaluation.

AFRINIC applies a slow start mechanism for all new LIRs (Local Internet Registries). When making initial allocations, the first allocation an LIR receives will be the size of the minimum practical allocation described in Section 8.2 (a), unless there is appropriate justification for a larger allocation.

The slow start policy is universally used by all Regional Internet Registries (RIRs) to prevent the rapid allocation of large address blocks that might remain underutilized. AFRINIC consistently and fairly applies the slow start mechanism to every LIR and applies the same principles and standards to all applicants for address space.

Additional Allocation requirements:

An LIR may be eligible for an additional allocation when approximately 80% of all the address space currently allocated to them has been used in valid assignments and/or sub-allocations. Alternatively, a new allocation can be considered if a single assignment or sub-allocation requires more addresses than the LIR currently holds.

Can I lease out the IPv4 addresses allocated by AFRINIC?

On May, 2022 in the CEO’s monthly update, the CEO of AFRINIC Eddy Kayihura pointed out that the allocation of IP Number Resources is strictly based on the principle of strict need, in accordance with the provisions stated in the Registration Service Agreement (RSA). As responsible members, it is essential to inform AFRINIC of any changes that might impact the allocated IP Number resources and promptly surrender any resources that are no longer required. Moreover, in this update he emphasized that stockpiling of allocated IP number resources is strictly prohibited, as clearly stated in the Consolidated Policy Manual (CPM).

Taking into account the case with Cloud Innovation Ltd and the statement above, we do not recommend to lease out IPv4 subnets allocated by AFRINC: thus can be considered as a breach of the RSA.

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