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 (personal names or initials). 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.

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

Requirements for Your Communications

As you have confirmed that you are responsible for dispatching communications and updating your customers' data, you must send emails to all your registrar-managed registrants that are registered as a company.

Follow up required:

To confirm that all registrants have received the update information, you must submit a list to us of all the registrants you have contacted. This list must include, at a minimum: Company Name, Domain Name, and Email Address. Please send the list to registrar@punktum.dk.

Actions You MUST Take as a Registrar:

Send Emails: You must send emails to all your company customers, both those registered with and without a CVR/VAT number.
Public Email Address: 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.'
Handle Bounced Emails: In cases where an email does not reach the registrant but bounces back, and you have an alternative email address, send it to that address. If you do not have another email address, you must obtain one, as the registrant will otherwise not have correct contact information.
Add Secondary Email (Recommendation): If your customers do not have two email addresses, we recommend that you promptly add an additional email address for them in the registrar portal.
Deadlines: Registrants have until September 1, 2025, to check/update their contact information. You must have sent emails to registrants no later than August 1, 2025.
Provide Guidance: It is important that you, as the registrar, guide registrants on how they can check and, if necessary, change their information, including the email address.
Assist with Updates: You must assist your registrar-managed customers with updates, as this information cannot be updated in Punktum dk’s self-service portal.
Foreign Sole Proprietorships: If the company is a foreign sole proprietorship, the company must submit documentation for this so that Punktum dk has the option to refrain from publishing the 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 that this is not supported via EPP.
Maintain Accurate Contact Information: Correct contact information remains a requirement: It is still crucial that name, address, phone number, and email address are always correct and updated with us.

Information the Registrant MUST Be Clearly Informed Of:

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).
The public email address must not contain personal data (e.g., your name or initials).
You must check that the information is correct (name, address, phone number, and email address).
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.
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.