The RIPE NCC has permitted members to operate multiple Local Internet Registry accounts under a single membership since its early days. Originally designed to serve a small number of organizations with distinct business units or those that had undergone mergers while maintaining separate operational structures, this flexibility has since created persistent complexity across the registry's systems and processes.

The hierarchical Internet Registry System, established in the early 1990s to manage the Internet's explosive growth, assigns Regional Internet Registries responsibility for distributing address space within their service regions. These RIRs allocate resources to Local Internet Registries—typically Internet Service Providers, academic institutions and enterprise networks—which in turn assign address space to end users. The foundational assumption underlying this model and the policies built around it was straightforward: one organization operates one LIR account.

The RIPE NCC diverged from this approach by accommodating requests from members seeking additional accounts to streamline internal administration. For many years, this exception remained manageable. The number of supplementary accounts stayed relatively stable at 100 to 150, and operational impact remained limited.

IPv4 scarcity transformed the equation

In September 2012, the RIPE NCC exhausted its last available /8 of IPv4 address space. Under the policy in effect at that time, each LIR became entitled to a single final /22 allocation from the remaining pool. This policy was written with the assumption that each LIR represented a single member organization.

As IPv4 became scarce and its market value climbed, an economic incentive emerged that the original policy architects had not anticipated. Once the value of a /22 exceeded the cost of establishing and maintaining an LIR account, creating additional accounts became financially attractive. A small number of members recognized this opportunity quickly. Importantly, this was not a policy violation but rather a consequence of how the RIPE policy interacted with the RIPE NCC's operational model.

Initially, the number of additional accounts remained relatively stable because members could open an account, receive their /22, transfer it almost immediately, and close the account shortly afterwards. Many accounts therefore existed only briefly and did not appear as a significant increase in overall statistics.

This changed in July 2015 when policy proposal 2015-01 introduced a 24-month holding period before IPv4 allocations from the RIPE NCC could be transferred. Members now had to keep additional accounts open for at least two years, which fundamentally altered the economics of the practice. The number of additional LIR accounts began to rise.

In November 2015, the RIPE NCC Executive Board temporarily suspended the creation of additional LIR accounts and asked the membership to decide whether the practice should continue. Analysis showed that most additional accounts were being created to obtain extra /22 allocations for later transfer, which was clearly not the original intent of the last /8 policy. However, the Board concluded that prohibiting additional LIR accounts might simply encourage organizations to create multiple legal entities instead, each becoming a separate RIPE NCC member. That alternative would reduce transparency and affect RIPE NCC governance, since each member carries its own vote. The Board subsequently recommended allowing multiple LIR accounts again, and the membership voted in favor at the General Meeting in May 2016.

This decision chose the more pragmatic of two imperfect options. While it helped maintain organizational transparency, it left the financial incentive untouched.

As IPv4 prices continued rising from 2016 onwards, the number of additional LIR accounts reached unprecedented levels. By late 2019, more than 5,500 additional accounts existed, representing over 20% of all LIR accounts. Some organizations held only one or two additional accounts, but a relatively small number of members opened dozens simultaneously. Many of these accounts were closed shortly after the 24-month holding period expired, with the associated /22 being transferred almost immediately. This pattern strongly suggested that accounts had primarily been created to obtain transferable IPv4 address space.

The peak arrived in November 2019, which was also when the RIPE NCC exhausted its remaining IPv4 pool. The policy changed again: from then on, only LIRs that had never received IPv4 from the RIPE NCC could receive a single recycled /24 allocation. A /24 was worth considerably less than a /22, and demand for additional accounts declined. The overall number began to fall, though with the expected delay caused by the 24-month holding period.

This trend reversed in 2021 when IPv4 market prices increased once more, making even recycled /24 allocations commercially attractive. A few members once again opened dozens of additional accounts simultaneously, as the economic benefit grew with the number of accounts. Only from late 2023 onwards did the number of additional LIR accounts begin to decline significantly again, following a sustained decrease in IPv4 market prices.

The close correlation between IPv4 market prices and the number of additional LIR accounts suggests that while some organizations might have administrative reasons for operating multiple accounts, the primary driver behind their rise was economic rather than operational.

Testing the 2016 assumptions

When the membership voted in May 2016 to lift the temporary suspension, the decision rested on three key assumptions. Nearly a decade of operational experience provides a basis for evaluating how these assumptions held in practice.

The first assumption was that maintaining additional LIR accounts under the same membership would provide greater transparency than encouraging organizations to create multiple legal entities. The availability of additional LIR accounts may have reduced the incentive to create multiple memberships, but it never removed that possibility. Organizations willing to establish multiple legal entities could still do so. In practice, most chose the easier option of opening additional LIR accounts whenever this became economically attractive. Furthermore, creating and maintaining multiple legal entities has since become increasingly complex in many economies. Regulatory requirements, tax obligations, transparency rules and Know Your Customer requirements have all become more stringent, making this a considerably higher barrier than simply opening an additional LIR account.

Transparency has also evolved considerably since 2016. The RIPE NCC has significantly strengthened its KYC processes over the past decade, driven by both operational needs and regulatory requirements including sanctions compliance. As a result, the RIPE NCC today has considerably better visibility into who controls member organizations than was the case when the 2016 decision was made.

The second assumption was that remaining issues could be resolved through policy changes. This proved difficult to realize. Discussions within the RIPE community concluded that the issue was not so much a policy loophole, but rather the RIPE NCC's operational decision to allow multiple LIR accounts under a single membership. Since RIPE policies are fundamentally written around the concept that an LIR represents a single member organization, there was little appetite to redesign the broader policy framework to accommodate this operational exception.

The assumptions made in 2016 were reasonable given the information available at the time. However, nearly a decade of operational experience since then shows that the practical outcome differed in several important respects. Rather than reducing complexity, the operational exception for multiple LIR accounts continued to create strong economic incentives and increased operational overhead for the RIPE NCC, while changes in regulation and the RIPE NCC's own processes reduced some of the concerns that originally supported maintaining this model.

The operational cost of maintaining an exception

The number of additional LIR accounts tells only part of the story. Equally important is the operational complexity created by maintaining an exception to the original one-member–one-LIR model. For many years, this complexity remained manageable through individual process improvements and system enhancements. However, as the RIPE NCC continued to modernize its services and automate more operational processes, supporting multiple LIR accounts under a single membership became an increasingly expensive exception.

Most RIPE NCC systems were originally designed around the assumption that a registry account represents one member organization. Allowing several registry accounts for the same member introduces complexity at almost every layer of the organization.

  • Fragmented member information. Contact details, billing entities, maintainers and communication preferences can differ between LIR accounts belonging to the same organization, making it harder to maintain a consistent view of a member.
  • Higher administrative workload. Activities such as audits, account closures, resource transfers and member updates often need to be handled separately for each LIR account, requiring additional coordination and manual effort. Additional checks are also needed before each General Meeting to ensure that voting rights associated with a member are correctly assigned to the primary LIR account and denied to additional accounts, preserving the one-member-one-vote principle.
  • More complex systems. Information such as resource holdings, sponsorship relationships and administrative records is managed at the LIR account level, while other processes operate at the member level. This makes even relatively small system changes significantly more complicated to design and implement.
  • Additional billing and compliance effort. Different invoicing arrangements, contacts and payment responsibilities across multiple accounts increase the complexity of financial administration, compliance activities and fraud prevention.
  • Resource management overhead. Multiple accounts encourage fragmentation of Internet number resources, often followed by later consolidation efforts that require additional work for both members and the RIPE NCC.
  • Distorted perception of membership costs. A large number of multiple LIRs brings in additional fees, while any budget surplus is typically redistributed to the membership as a discount on the next year's fees. Members who joined in the period between 2016-2022 therefore formed a distorted perception of what 'normal' fees looked like, which created friction in charging scheme discussions.

None of these challenges are overwhelming on their own. Together, however, they create a continuous operational cost that affects system development, process design and day-to-day registry operations. Especially in times of increased cost awareness and requests for more efficient use of the funding provided by members, this is too significant to ignore. Could all of these issues be solved technically and operationally? Probably. But doing so would require significant investment into supporting an operational model that differs from the one on which the Internet Registry System and the RIPE policy framework is built.

A window of opportunity

Ironically, just as the operational costs have become increasingly apparent, the scale of the issue has become much smaller. Following the peak in 2019, the number of additional LIR accounts has steadily declined, largely due to changing economic conditions: IPv4 prices fell, while the cost of maintaining LIR accounts increased. As a result, opening new additional accounts became less attractive, and many organizations closed accounts that had originally been created to obtain additional IPv4 allocations.

Today, the picture looks very different from just a few years ago. On 1 August 2026:

  • 410 members (approximately 2.1% of the membership) operate multiple LIR accounts.
  • Together they hold 708 additional LIR accounts, representing 3.4% of all LIR accounts.
  • During the last 24 months, only 41 members opened additional accounts, creating 67 new LIR accounts in total.

From a membership perspective, this has become a relatively niche issue. Yet the operational complexity described above remains embedded in the RIPE NCC's systems and processes, affecting the organization as a whole. This creates an interesting situation. The impact on members has become smaller than ever, while the benefits of simplifying the operational model have increased.

At the same time, this opportunity may not remain open indefinitely. As long as additional LIR accounts remain possible, changing market conditions or future charging models could once again make opening additional accounts economically attractive. The experience of the past decade has shown just how quickly such incentives can influence behavior.

While the operational burden is permanent, the current low number of additional LIR accounts presents a rare opportunity to address the issue with relatively limited impact on the membership. The RIPE NCC believes that now is the time to raise this topic with the RIPE community for further discussion and to hear from members who still use multiple LIR accounts. A presentation is planned for RIPE 93 later this year. In the meantime, comments are welcome on the RIPE NCC Services Working Group mailing list.