Thank you to those of you who participated in the online NIS2 technical registrar meeting this October. During the meeting, several important questions arose regarding the new NIS2-driven features that will be released and active starting January 14, 2026.
These new features will enable registrars to handle registrant data verification directly.
We want to clarify that while these features will be available on January 14, Punktum dk does not require registrars to have implemented and begun using them within their EPP systems or Registrar Portal on that specific date. Implementation by registrars can follow later.
Regarding the questions - they have been clarified and to ensure full transparency and compliance across our registrar base, the specific questions raised, and their corresponding answers, are presented to you.
The following is a list of the questions that were raised. You can review the clarifications in the Q&A section here.
Do verification requirements allow registrars to verify only certain fields of a registrant's information?
Does Punktum dk still conduct registrant data verification even if the registrar has already verified the information upfront?
If a registrar uses the EPP/RP to confirm a new contact as already verified, will Punktum dk subsequently perform a risk assessment that automatically could trigger a second, mandatory verification for that same registrant?
When does the registrant's email need to be verified?
Does Punktum dk verify primary or secondary e-mail address?
Why does Punktum dk require mandatory CVR/CPR lock for Danish registrants, and what are the risks of relying solely on the data supplied by registrars?
Follow the links below to read the referenced documents Main Document NIS2 including Appendix and Summary from the referred the Working Group:
Summary from the working group meetings: 3, 4, 6, 7, 8, and 12 Here
Main document_NIS2 ART. 28 including Appendix 2_NIS2 Technical working group and Appendix 1_NIS2 Approved verification methods Here
Please don't hesitate to reach out if you have any questions.