Internet Governance After Ukraine-Russia Conflict


Date: April 22, 2022 14:00-16:00


  • Kwo-Wei Wu, Chairman of Taiwan Internet Governance Forum (TWIGF)
  • Panelists:
  • Tsung Han Wu, Assistant Research Fellow, Institute for National Defense and Security Research
  • Xin-Xiong Shen, Senior Technical Specialist of National Communications Commission
  • Ken-Ying Tseng, Attorney-at-Law of LEE AND LI
  • Kenny Huang, CEO of Taiwan Network Information Center (TWNIC)

Session details

One week after Russian invasion of Ukraine, Ukraine government representative sent letters to ICANN (Internet Organization for Assigned Names and Numbers) and RIPE NCC asking to introduce sanctions against Russian in the areas of DNS and Ipv4 and Ipv6 address. The requests include revoking the domains of “.ru”, “.рф” and “.su”, shutting down DNS root servers situated in the Russian and withdraw the right to use all IPv4 and IPv6 addresses by all Russian members.

RIPE NCC and ICANN have both rejected Ukraine’s requests as they do not change the Internet resources management by political factors.  The panel invited experts with rich internet policy making experiences to talk about how the Internet governance institutions respond to the Ukraine-Russia conflict, explore the possible changes of global Internet governance principles, and identify key factors Internet community in Taiwan may pay attention to in the future.


The Moderator Kwo-Wei Wu opened the session with a brief background introduction mentioning that the requests from Ukraine Government were rejected by the 2 international Internet resource organizations.  He invited the panelists to discuss issues from the perspectives of regulations, technology and Taiwan’s position. 

Dr. Kenny Huang was asked to explain about the fundamental TLDs (top-level domains) reference: RFC 1591 – Domain Name System Structure and Delegation.   “RFC 1591 is a reference guide for defining all types of TLDs, including generic TLDs (gTLDs), United States only generic domains as well as the two-letter country-code TLDs (ccTLDs).  The naming of ccTLDs is based on the ISO 3166-1 standard.   There is no specification in the RFC regarding who is eligible to apply for the ccTLDs, if the significantly interested parties (such as governments) of the domain name agree that the designated manager is the appropriate party.” However, Dr. Huang further indicated that, “RFC is not internationally mandatory standards, but adopted voluntarily.”

Ken-Ying Tseng, Attorney-at-Law of LEE AND LI, referred ICANN’s GAC (Governmental Advisory Committee) document titled “Principles and Guidelines for the Delegation and Administration of Country Code Top Level Domains”.  She said, the GAC document, which was written based on RFC 1591, mainly describes the tripartite relationship among ICANN, the government or public authority and the ccTLD registry.   Tseng further stated that, “ccTLD is a national/local matter, when an abuse occurs, domestic/local law will be applied. ICANN will maintain a neutral and hands-off stance.”  As a result, ICANN is not in the position responding to the Ukrainian government’s request.  “However, this event bring to mind that we need to face up to the ccTLD governance matter.”, concluded by Kuo Wei Wu.

Xin-Xiong Shen, from the regulation body,  supports the decision of ICANN and RIPE NCC not to revoke Russia’s ccTLDs and IP addresses.  “Taiwan stands difficult position internationally, any decision made based on political factors is not good for the country.”

Dr. Tsung Han Wu, a research fellow from the defense think tank, believes that Ukraine’s request to ICANN is just one of the country’s strategic IT operations.  Dr. Wu deliberated that, rather than blocking Russia from the Internet, the true purpose is to impose more international pressures to Russia.  “What we can learn from Ukraine in this matter is the application of multiple approaches to impose pressures on the aggressors.”

Dr. Kenny Huang further explained that it is technically feasible for ICANN or any government to block another country’s ccTLD, while the issue lies in the legal applicability.  The economic sanctions against Russia imposed by the European Union, the United States and its allies are legally bind. It is notable that some countries consider Domain Name and IP Address as virtual assets and they are applicable to the economic sanctions.  As a result, IP addresses referring to more than 700 individuals and entities in Russia, including the country’s top three telecom operators, were blocked as the implementation of economic sanction.  If the scope of the sanction extends in the future, it is possible that RPKI (Resource Public Key Infrastructure) be invalidated and dis-function the Internet routing in Russia.  In addition, although ICANN rejected Ukraine’s request, chairman of ICANN Board announced future removal of .SU ccTLD for the reason of the code is no longer listed in ISO 3166.  Possibly for supporting the Ukraine government’s request?

Kuo-Wei Wu further reminded that, many countries block the Internet to a certain extent, especially China and Russia.  By restricting the inbound traffic while allowing their hackers launch cyberattacks or interfere major elections to the United States and Taiwan.  In the recent conflict, Russia also cyberattack Ukraine’s finance and telecommunications organizations, which can be considered as cyber war.  Wu commented, “when imposing a cyber sanction, we should not only consider it might interfere Russian people’s access to the true information.”

Xin-Xiong Shen also commented that, in the case of Taiwan’s Internet is under attack and the society functions are affected, he is in favor of blocking the attackers’ network.  “There are always other ways for truth dissemination,” Shen added.

China and Russia both claim their own Internet sovereignty, when cutting off Internet connection to Russia, Russia will take it as a justification to officially launch its independent national Internet: RuNet. Said Dr. Tsung Han Wu as respond to Kuo-Wei Wu’s reminder.

The panel went further to cover Taiwan’s other Internet connectivity issues, including submarine cables and communication satellites.  The moderator started the discussion by referring to The Wall Street Journal’s commentary article.  The article pointed out the war in Ukraine raised Taiwan’s concerns regarding the vulnerability of Internet connections.

Dr. Kenny Huang commented that, Ukraine is a land country and has no submarine cable problem. Although the communication facilities were destroyed in the early days of the war, they are immediately repaired.  Moreover, SpaceX also offered Starlink low-orbit satellite services.  In general, Ukraine’s Internet connection is good.  “Taiwan’s submarine cable is riskier”, said Dr. Hung, “although satellite Internet is in place, it will be insufficient in capacity.  As result, Taiwan should set up priorities for satellite development, such as for Internet access, for military-only purpose and so on.”

Dr. Tsung Han Wu shared the same view with Dr. Huang regarding the vulnerable submarine cable problem in Taiwan. He explained, not only because the cable repairing cost is high, but also very few suppliers globally.  Not mentioning Chinese suppliers are part of the very few. “Taiwan needs to think about the countermeasures.” Dr. Wu suggested.

Xin-Xiong Shen point out the lack of interests of foreign satellite Internet service providers to Taiwan’s market and the island has an extremely high Internet penetration in the world.  In addition, the national security concerns for foreign investment, requirements such as local landing and capital limitation may make our market less attractive.  Taiwan may also face a problem applying for satellite orbits and frequencies from the United Nations body – ITU (International Telecommunication Union).

Ukraine uses Starlink solution in the wartime for Internet, it is like handing over the whole country’s Internet traffic to an American company.  Kwo-Wei Wu suggested Taiwan’s satellite Internet regulation should seek balance between national security and communication needs.  

Dr. Huang reminded that “Peacetime” and “wartime” are two different scenarios: the “normal” regulatory requirements are for the purpose of protecting the consumers; while in the “wartime”, there will be other rules applied.  He further concluded that, the existing international legal system is very flexible. For example, the way countries expand the scope of economic sanctions to virtual assets is new attempt.  Internet governance is even more flexible, and even if the official response of the international institutions looks rigorous, various “inclined” measures as mentioned can be taken. In addition, an Internet sanction principle was proposed, suggesting having a blacklist of domain name and IP address used by the military and propaganda agencies of the aggressor country. It is believed that many countries have already started to develop this sanction list.

“In the past, domain names and IP address were considered as public goods, in the Ukrain-Russian war, they are for the first time to be considered as economic sanction targets. It is a giant change since Internet governance debate in 1998.  It also highlights the different approaches taken when facing the new Internet governance challenges.” Kwo-Wei Wu concluded the session.







  • 吳國維 理事長(台灣網路治理論壇)


  • 吳宗翰 博士(國防安全研究院)

  • 沈信雄 簡任技正(國家通訊傳播委員會)

  • 曾更瑩 合夥人 ( 理律法律事務所)

  • 黃勝雄 董事暨執行長(台灣網路資訊中心)



此次烏俄戰爭,烏克蘭政府請求ICANN(網際網路名稱與號碼指配機構)制裁俄羅斯,關閉其ccTLD(國家頂級域名),也就是.ru、.рф及.su;另也請求歐洲IP位址管理機構 RIPE NCC,取消俄羅斯IPv4與IPv6位址的使用權。但這些訴求遭到拒絕。本次座談從法規面、技術面和台灣立場等角度,探討相關問題。

通信協定標準文件《RFC 1591 域名系統架構和授權》(Domain Name System Structure and Delegation)是規範TLD(頂級域名)要件的參考指引,內容包含列出.edu和.org等gTLD(通用頂級域名),並說明ccTLD(國家頂級域名)是參照國際標準組織ISO的3166-1清單制定,但沒有訂定誰可以申請ccTLD,只要是該域名的重大利害關係方(如政府)同意即可。惟RFC和ISO皆非國際強制性標準,而是自願採用性質。

ICANN之GAC(政府諮詢委員會)《ccTLDs授權與管理之原則和指南》(Principles and Guidelines for the Delegation and Administration of Country Code Top Level Domains)是基於RFC 1591制定的,主要是規範ICANN、政府或公權力當局、ccTLD註冊管理局,3個利害關係方之間的角色和關係,並載明ccTLD是各國/在地議題,如果發生爭議,是訴諸國內/在地法律,ICANN則維持中立且不介入的立場。



以臺灣的國際立場和政府角度而言,應是支持ICANN和RIPE NCC沒有撤銷俄羅斯的ccTLD和IP位址,因為任何基於政治因素的撤銷措施都不利於臺灣,即使我們有.tw作為ccTLD,但ISO 3166-1仍加註是「中國省份」,因為ISO屬於聯合國組織。



ICANN或各國政府如要屏蔽另一國的ccTLD,技術面並無太大困難,問題在於法律的適用性。目前有法律依據的國際禁制令,包括聯合國通過譴責俄羅斯及其相對應的約束措施,以及歐盟、美國及其盟友對俄羅斯的經濟制裁;尤其歐美陣營佔全球GDP的70%,制裁力量不容小覷。當中值得關注的網路治理議題,是域名和IP史無前例地被歐美擴大解釋為經濟制裁的項目。雖然ICANN和RIPE NCC檯面上婉拒烏克蘭的請求,但前者近期已以.su不在ISO 3166-1上為由,正考慮將其移除;後者也依歐盟的制裁清單,將和普丁政權相關的700多個個人或實體(包括俄羅斯前三大電信業者)的IP位址凍結,未來如再進一步擴大解釋,還可使IP上的RPKI(資源公鑰基礎建設)失效,讓俄羅斯的路由無法接通。








烏克蘭是陸路國家沒有海纜問題,雖然戰爭初期通訊設施也遭攻擊,但在電信公司立即搶修,加上美國 SpaceX 公司提供星鏈(Starlink)低軌衛星網路設備的援助下,烏克蘭的網路通訊狀況良好。而臺灣海纜的風險則較大,儘管也可使用衛星通訊,但有總乘載量不足的問題。所以,我國應從法規制度面和技術面,探討使用衛星通訊的優先項目、軍民共用或軍方單獨使用,及如何符合軍方嚴格的加密規定等問題。