The Annual Independent Audit report posted today by ICANN notes two non-compliances (which may be considered minor), and makes no statement on requirements H.V.1, H.V.2, H.V.4, I.2 due to lack of historical records. These requirements refer to appendices H and I of the registry agreement.
The requirements from appendix H: V. ACCESS TO THE REGISTRY FACILITY VGRS provides access to all VGRS customers through the following mechanisms and separates VGRS systems and information from systems and information of any affiliated registrar through these processes: 1. All registrars (including any registrar affiliated with VGRS) connect to the Shared Registration System Gateway via the Internet by utilizing the same maximum number of IP addresses and SSL certificate authentication. 2. All registrars have the same level of access to VGRS-generated data to reconcile their registration activities from VGRS Web and ftp servers. All registrars may perform basic automated registrar account management functions using the same registrar tool made available to all registrars by VGRS. [...] 4. No registrar affiliated with VGRS will be given any access to the registry not available to any other registrar except with regard to information specific to their registrar.
The requirement from appendix I: 2. All registrars accredited by ICANN who are authorized to register domain names in the {.com,.org,.net} registry shall have equivalent access to Registry Services provided by VGRS.
