Applicant Information
| Full Legal Name: |
Tucows.com Co |
| Doing Business As: |
Tucows Registry Services |
| Business URL: |
https://www.tucowsregistry.com/ |
| Primary Business Phone: |
+1 800 371-6992 |
| Primary Business Email: |
ry-services@tucows.com |
| Country Code of Location: |
CA |
| Application Type |
DNSSEC |
| Application Status |
Cleared |
| Technical Screening Status |
Cleared |
| RST Status |
Cleared |
DNSSEC.1.1.Third-Party Certificate
Does or will this RSP have a publicly verifiable, third-party certification (e.g. ISO 27001) held directly by the organization and relevant to the registry services under application?
Response
Yes
DNSSEC.1.3.Physical Access Controls
Does or will this RSP have processes and controls to manage physical access to infrastructure and systems, including building access controls, security cameras and/or other sensors, physical environmental monitoring and safety equipment, and alarm systems related to the physical infrastructure?
Response
Yes
DNSSEC.1.4.System Access Controls
Does or will this RSP have processes and controls to manage non-physical access to infrastructure, including network access from both internal systems and external Internet systems, intrusion detection systems, security information and event management systems, network firewalls, network segmentation and isolation, user identification and authentication, and authorization schemes?
Response
Yes
DNSSEC.1.5.Vendor Management
Does or will this RSP have processes and controls pertaining to the selection of vendors and equipment suppliers, management and maintenance of assets while in use, procurement of assets, and safe disposal of assets?
Response
Yes
DNSSEC.1.6.Cryptographic Material
Does or will this RSP routinely renew and keep safe all cryptographic material necessary for the operation of the RSP?
Response
Yes
DNSSEC.1.7.Secure Data At-Rest
Does or will this RSP secure (e.g. encryption, tamper detection, etc…) at-rest data relevant to the operation of the RSP, including but not limited to DNSSEC if applicable?
Response
Yes
DNSSEC.1.8.Secure Data In-Transit
Does or will this RSP secure (e.g. encryption, tamper detection, etc…) in-transit data relevant to the operation of the RSP, including but not limited to DNSSEC if applicable?
Response
Yes
DNSSEC.1.9.Virtualization Controls
If applicable, does or will this RSP have security controls for data in virtualized environments, including controls relevant to both on-premises or private virtualization environments as well as public clouds, network isolation, memory isolation, process isolation, and hypervisor access controls?
Response
Yes
DNSSEC.1.10.CISO
Does or will this RSP have a senior executive primarily in charge of and responsible for security?
Response
Yes
DNSSEC.1.12.Background Checks
Does or will this RSP conduct background checks, both initial and on-going, of personnel and vendors relevant to the registry services under application?
Response
Yes
DNSSEC.1.14.BCP 38
Does or will this RSP comply with BCP 38?
Response
Yes
DNSSEC.1.15.Secure Routing
Does or will this RSP implement routing security of some nature, such as automated route filters, RPKI route origin validation, or other operational practices defined by the Internet Society and Global Cyber Alliance’s Mutually Agreed Norms for Routing Security (MANRS)?
Response
Yes
DNSSEC.2.2.Standard Hardware Maintenance
Does or will this RSP have documented, regular, and active practices for the maintenance of hardware relevant to the registry services under application?
Response
Yes
DNSSEC.2.3.Standard Hardware Lifecycle
Does or will this RSP have documented, regular, and active practices for the maintenance, upgrading, and patching of software relevant to the registry services under application?
Response
Yes
DNSSEC.2.4.Standard Hardware Lifecycle
Does or will this RSP have documented, regular, and active practices for the lifecycle of hardware relevant to the registry services under application?
Response
Yes
DNSSEC.2.5.Secure Software Development
Does or will this RSP have documented, regular, and active practices for the secure development of software?
Response
Yes
DNSSEC.2.6.Hardware Maintenance Contingency
Does or will this RSP have documented contingency plans for extraordinary scenarios regarding the maintenance of hardware relevant to the registry services under application?
Response
Yes
DNSSEC.2.7.Software Maintenance Contingency
Does or will this RSP have documented contingency plans for extraordinary scenarios regarding the maintenance, upgrading, and patching of software relevant to the registry services under application?
Response
Yes
DNSSEC.2.8.Hardware Lifecycle Contingency
Does or will this RSP have documented contingency plans for extraordinary scenarios regarding the lifecycle of hardware relevant to the registry services under application?
Response
Yes
DNSSEC.2.9.Software Development Contingency
Does or will this RSP have documented contingency plans for extraordinary scenarios regarding the development of software?
Response
Yes
DNSSEC.2.10.IaC
Does or will this RSP use Infrastructure-as-Code (IaC) to manage all systems relevant to operation of the registry services under application?
Response
Yes
DNSSEC.2.11.Automated Orchestration
Does or will this RSP use automated orchestration to manage all systems relevant to the operation of the registry services under application?
Response
Yes
DNSSEC.3.3.Tier III Data Center
Does or will this RSP have at least two Tier III (as defined here: https://uptimeinstitute.com/tiers) or equivalent data centers having no inter-dependencies?
Response
Yes
Attachments
DNSSEC.3.9.FIPS 140-3
Does or will this RSP use hardware security modules (HSMs) certified to at least FIPS 140-3 Level 3?
Response
Yes
DNSSEC.4.3.RFC 4033
Does or will this RSP implement RFC 4033 (“DNS Security Introduction and Requirements”)?
Response
Yes
DNSSEC.4.4.RFC 4034
Does or will this RSP implement RFC 4034 (“Resource Records for the DNS Security Extensions”)?
Response
Yes
DNSSEC.4.5.RFC 4035
Does or will this RSP implement RFC 4035 (“Protocol Modifications for the DNS Security Extensions”)?
Response
Yes
DNSSEC.4.6.RFC 4509
Does or will this RSP implement RFC 4509 (“Use of SHA-256 in DNSSEC Delegation Signer (DS) Resource Records (RRs)”)?
Response
Yes
DNSSEC.4.7.RFC 6840
Does or will this RSP implement RFC 6840 (“Clarifications and Implementation Notes for DNS Security (DNSSEC)”)?
Response
Yes
DNSSEC.4.8.RFC 6781
Does or will this RSP implement RFC 6781 (“DNSSEC Operational Practices, Version 2”)?
Response
Yes
DNSSEC.4.9.RFC 7583
Does or will this RSP implement RFC 7583 (“DNSSEC Key Rollover Timing Considerations”)?
Response
Yes
DNSSEC.4.10.RFC 9276
Does or will this RSP implement RFC 9276 (“Guidance for NSEC3 Parameter Settings”)?
Response
Yes
DNSSEC.4.11.RFCs 6605, 5702, and 8080
Does or will this RSP implement any of RFC 6605 (“Elliptic Curve Digital Signature Algorithm (DSA) for DNSSEC”), RFC 5702 (“Use of SHA-2 Algorithms with RSA in DNSKEY and RRSIG Resource Records for DNSSEC“), and/or RFC 8080 (“Edwards-Curve Digital Security Algorithm (EdDSA) for DNSSEC”)?
Response
Yes
DNSSEC.4.14.KSK Rollovers
Describe the processes and procedures to be used to practice and ensure a successful KSK rollover for both emergency and non-emergency situations, including coordination with the MAIN RSP and IANA.
Response
TRS implements comprehensive KSK rollover procedures following RFC 6781 with coordination mechanisms for external MAIN RSP scenarios.
Typical KSK Rollover (RFC 6781 § 4.1.2):
Planning: DNSSEC RSP identifies rollover window (90+ days advance) accounting for DS TTLs, parent zone propagation, IANA processing.
New KSK Generation: Generate new KSK using HSM infrastructure (FIPS 140-3 Level 3 certified where required), verify through independent validation.
MAIN RSP Notification: Notify MAIN RSP via authenticated channel (PGP email, secure ticketing, mutual-TLS API) with rollover timeline, DNSKEY record, computed DS record.
IANA Submission: MAIN RSP validates DS against DNSKEY, submits to IANA, logs with timestamps.
Publication Monitoring: Both parties monitor parent zone for DS publication.
Signing: After DS published and propagated (24-48 hours), sign with new KSK while maintaining old KSK signatures during rollover period.
Old DS Removal: After trust establishment (7-30 days), MAIN RSP removes old DS.
Decommission: Remove old KSK from DNSKEY RRset after DS removal propagates.
Emergency KSK Rollover (RFC 6781 § 4.2.4):
For key compromise, HSM failure, or cryptographic vulnerabilities:
Emergency Activation: Pre-generated emergency KSK stored offline using M-of-N quorum (3-of-5 fragments geographically distributed). Authorized personnel retrieve fragments and reconstruct emergency KSK.
Immediate Notification: Notify MAIN RSP via emergency channels (24/7 hotline, emergency ticketing, encrypted messaging with out-of-band verification) with incident description, emergency KSK material, DS record.
Emergency DS Publication (two options):
Option A - Pre-Published: Emergency DS records pre-published in parent zone alongside production DS during normal operations, allowing immediate activation without IANA coordination. Pre-published DS remains dormant; emergency KSK offline until activation.
Option B - Expedited Coordination: MAIN RSP invokes expedited IANA processing (hours vs. days/weeks). IANA publishes emergency DS on accelerated timeline.
Cutover: Upon DS availability (immediate for pre-published, 2-4 hours for newly published), cut over to emergency KSK immediately, remove compromised KSK.
Revocation: Apply REVOKE flag (RFC 5011) to compromised KSK for validator cache purge. MAIN RSP removes compromised DS (immediate for Option B; next maintenance for Option A).
Stabilization: After 24-48 hours, schedule planned rollover to permanent KSK. Decommission emergency KSK, generate new emergency KSK. For Option A, pre-publish new emergency DS.
Coordination Security:
Authenticated channels: PGP-signed email, mutual-TLS ticketing/APIs, OAuth 2.0, out-of-band phone verification. All DS submissions logged with timestamps, submitter ID, IANA responses, communication transcripts. MAIN RSP maintains redundant contact lists with 24/7 reachability.
Emergency KSK Protection:
Offline storage (never loaded until activation)
M-of-N fragments in geographically separated facilities (1500+ miles)
Tamper-evident containers with chain-of-custody
Annual validation that fragments reconstruct functional KSK
Access logging with video surveillance and biometric controls
TRS coordinates annual tabletop exercises with registry operators and MAIN RSPs testing emergency procedures.
Attachments
DNSSEC.4.15.DNSSEC Virtualization
Does or will this RSP compartmentalize (e.g. virtualization) the DNSSEC service in such a manner that each compartment (e.g. containers, virtual machines, physical machines) is dedicated to DNSSEC (excluding system services such as monitoring, remote access NTP)?
Response
Yes
DNSSEC.5.1.DNSSEC Service Continuity Exercise
Does or will this RSP regularly exercise DNSSEC service continuity actions?
Response
Yes
DNSSEC.5.3.Transfer of Operations
Does or will this RSP be capable of transferring all applicable operations to another RSP as defined by the Material Subcontracting Arrangement Technical Questions?
Response
Yes
DNSSEC.5.4.EBERO
Does or will this RSP participate in coordinated Emergency Back-end Registry Operator (EBERO) transitions, including but not limited to maintaining the DNSSEC chain of trust, of hosted gTLDs when the business relationship of this RSP and the Registry Operator is not in good standing?
Response
Yes
DNSSEC.6.1.Internal Monitoring
Does or will this RSP monitor for faults inside its own network?
Response
Yes
DNSSEC.6.2.External Monitoring
Does or will this RSP monitor for faults from a point outside any of its own networks?
Response
Yes
DNSSEC.6.3.Fault Triage
Does or will this RSP have documented processes for aggregation and triage of faults?
Response
Yes
DNSSEC.6.4.Fault Mitigation
Does or will this RSP have documented processes to mitigate faults once detected?
Response
Yes
DNSSEC.6.6.Fault Minimization
Does or will this RSP have processes to minimize faults during maintenance of systems, including both automated processes and manual change control processes?
Response
Yes
DNSSEC.6.7.On-call Staff
Does or will this RSP have personnel capable of reacting to and mitigating faults 24 hours per day of every day of every year of service?
Response
Yes
DNSSEC.6.8.Service Disruptions
Provide documentation regarding any RSP functions currently being served for any gTLD, the domain names of the gTLDs, and all service disruptions for each gTLD in the past six months, where a service disruption is defined by Specification 10 of the ICANN Registry Agreement (2024).
Response
TRS SRS has not experienced any service disruption.