[afnog] UCC Licensing Framework for IXPs

Mike Barnard mike.barnardq at gmail.com
Mon Jun 17 14:09:10 UTC 2019

The Uganda IXP (https://uixp.co.ug) recently received a letter from the
government (UCC) which announces that they intend to establish a licensing
framework for IXPs. The letter includes a detailed draft of the proposed
framework text (see attached).

While we think it is wise for the government to continuously reconsider its
role in this evolving industry in order to support its development, the
UCC's proposed licensing framework would ironically prohibit further market
development by effectively nationalizing the network interconnection

As written, the framework:

1) Establishes a government controlled monopoly IXP called the “Designated
National Internet Exchange Point” and requires all other IXPs to function
as edge nodes for it. The framework accomplishes this by requiring all IXPs
to connect to the DNIXP, and by giving government control over the
contracts between IXPs and their members. See 7.4.b; 8.2.a; 9.e.iii; 9.j.

2) Includes vague language which could lead to problematic interpretations.
For example: Clause 9.h could mean that the government intends for the
DNIXP to establish itself by expropriating the UIXP’s infrastructure.

3) Allows the government to inspect, copy, or remove any data related to
any IXP without a court order. This could include proprietary information.
See 7.5.b.ii.

4) Turns IXPs into potential surveillance hubs by requiring them to report
any unlawful activity observed in member networks to the government. See

5) Introduces other significant barriers to entry for new market entrants.

Our view is that this licensing framework should either be (a) scrapped
entirely, as it can be argued that it is counterproductive to license IXPs
in the first place or (b) significantly revised such that it no longer
includes any language which would create a monopoly or otherwise hinder the
emergence of true competition in this industry.

The UCC has called for written feedback to be submitted by July 5th, 2019
and we need your help to avoid disaster. Please take a few minutes to
review the attached document and submit your comments in writing before the
deadline. If you cannot submit feedback to the UCC directly, please send it
to us (board at uixp.co.ug) and we will ensure that it gets delivered to the
UCC in writing.

Thank you.
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