Dear Registrar,

We are contacting you because new regulations are approaching that require us to ensure registrant contact details are accurate and that company email addresses do not contain personal data. This is a direct consequence of the NIS2 Act, which comes into force on July 1, 2025. The Act implements the underlying NIS2 Directive, which aims to strengthen cybersecurity across the entire EU.

All company email addresses will, as a rule, be displayed in Punktum dk's public WHOIS database by September 1, 2025, at the latest.

In July, Punktum dk will send emails requesting an update of the email address to registrants registered as companies.

Emails will be sent to all user IDs. If a registrant has more than one user ID, they will therefore receive the email multiple times. In cases where an email does not reach the registrant but bounces back, and we have an alternative email address, we will send the message to that address instead.
The email address that will be publicly disclosed in WHOIS is currently known as the 'secondary email address.' This will be renamed to 'public email address.'

We will instruct registrants to complete the following actions within 30 days:

1. As you are registered as a company with Punktum dk, your email address will be publicly disclosed from September 1, 2025, in Punktum dk's public database (WHOIS).

2. The public email address must not contain personal data (e.g., your name or initials).

3. You must check that the information is correct (name, address, phone number, and email address). If you do not have a CVR/VAT number registered, you are asked to add your CVR/VAT number to your profile if you have one.

4. You must check your email address and review it for personal data and change the email address so that it does not contain personal data, if applicable.

5. If you are a foreign sole proprietorship, you must submit documentation for this to your registrar*, so that Punktum dk has the option to refrain from publishing your email address.

*As registrars, you will receive documentation on this from the registrant, and subsequently, you must confirm that it is a sole proprietorship in the registrar portal (before September 1, 2025). Punktum dk is in the process of implementing support for this. Please note this is not supported via EPP.

What Punktum dk Will Do

Email Dispatch: We will send emails to each user ID for registrants registered as companies, in batches, throughout July.
Registrar Identification: We will inform registrants who their registrar is, and that the registrar will be able to assist with the update.
WHOIS Publication: We will publish information in WHOIS on September 1, 2025.

Please note: In cases where an email does not reach a registrant but bounces back, and the customer has provided a secondary email address, we will send the message to this address instead.

If your customers do not have two email addresses, we recommend that you promptly add an additional email address for them, via the registrar portal or EPP.

NB: Should an email to the registrant prove to be invalid (e.g., if its "bounces"), we will contact you and request an updated email address. This is to ensure that the registrant receives the necessary information about the changes.

You can see the DRAFT of what Punktum dk will send out to registrar managed registrants here

Please feel free to contact us if you have any questions.

Best Regards,

Elin Smeby
Relationship Manager