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CPE, auctions, and the 2026 gTLD round: a complete guide

·Balazs Nemethi
#icann#cpe#agent#auction#subpro#gtld#community
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CPE, auctions, and the 2026 gTLD round: a complete guide

On 30 April 2026, ICANN opens the application window for the second round of new generic top-level domains. It closes 105 days later, on 12 August. Anyone who wants to run a string like .agent, .api, .robot, .padel, or .anything pays USD 227,000 to enter, and then waits out an evaluation that typically runs 14 to 20 months. Longer if the string is contested.

This post is a single-document reference for that process. It covers the lifecycle, what gets evaluated, how disputes get resolved, Community Priority Evaluation (CPE) in detail, auctions of last resort, fees, and timing. Sources: the 2026 Applicant Guidebook (v1-2025.12.16, published 16 December 2025), ICANN board materials and announcements, the 2012-round CPE scoring reports, and independent reporting from Domain Incite, CircleID, and Domain Name Wire. Every factual claim is cited at the bottom.

The argument running through all of it is simple. For the first time since 2012, the next round of gTLDs is friendlier to community-backed applications than to well-funded speculators. The shift is structural. Private auctions are prohibited. The Applicant Support Program has expanded. Community Priority Evaluation is the only ICANN-sanctioned path to a community-by-contract registry agreement. The rules reward organization, not just capital. They still reward capital. But the balance has moved.

The 10,000-foot view

The rest of this post fills in that diagram.

Before you apply

There is no restriction on who can apply for a new gTLD in the 2026 round. Corporations, governments, nonprofits, and community consortiums are all eligible, subject to background screening and financial qualification. What you cannot do is apply anonymously. Every applicant's identity is published on Reveal Day.

The base fee is USD 227,000 per string. That is up from USD 185,000 in 2012, roughly 22% higher in nominal terms and closer to flat after inflation. The fee covers every standard evaluation ICANN runs on the application: background screening, financial qualification, technical review, policy evaluation, and Extended Evaluation if any element needs remediation.

It does not cover registry-service-provider fees, legal counsel, objection filings, auction bids, or post-delegation operational costs. Practitioner rough estimates run USD 300,000 to USD 400,000 for a simple uncontested standard application, and USD 500,000 to USD 1,000,000+ for a contested or high-volume public TLD.

The only community-specific fee is Community Priority Evaluation itself: USD 50,000 to USD 80,000. That fee is only payable if contention develops and the applicant elects CPE rather than go to auction. Electing CPE is a 30-day window decision, documented in detail below.

The Applicant Support Program (ASP) offers qualifying applicants a 75% to 85% reduction on the base fee, effectively bringing a USD 227,000 application down to USD 34,050 to USD 56,750, plus pro-bono professional service access and an Applicant Counselor. The program targets financially-constrained applicants with a public-interest mission and was explicitly designed to redress the 2012 imbalance, where essentially no applications came from the Global South. The ASP window for the 2026 round closed on 19 December 2025, so the ASP cohort for this round is fixed. ICANN proposed in April 2026 to add USD 3.2 million in funding and raise the subsidy to 85%, responding to GAC and ALAC pressure on the program's geographic skew.

A separate pre-evaluation track exists for Registry Service Providers (RSPs), the technical vendors that run the DNS infrastructure behind a TLD. An RSP that has been pre-evaluated can be named on any applicant's submission without requiring ICANN to re-evaluate the backend stack. Major pre-approved providers include Identity Digital, Verisign, GoDaddy Registry, CentralNic, Amazon Registry, and (new in 2026) Unstoppable Domains. An applicant using one of these can skip the Section 7.9 technical evaluation.

The application window

The submission window opens at 23:59 UTC on 30 April 2026 and closes at 23:59 UTC on 12 August 2026. No late submissions. The USD 227,000 fee is due within 7 days of window close.

A submission has three sections: Organization Information, Financial Information, and gTLD Application Information, plus responses to roughly 50 substantive questions in Appendix 1 and supporting documents. The technical plan names the RSP stack (DNS, DNSSEC, EPP, RDAP, data escrow). Community applications must include draft Community Registration Policies, the eligibility and name-selection rules that will become Specification 12 of the Registry Agreement if the application prevails. Geographic-name applications must include government endorsement letters dated within four months of window opening.

Applicants may optionally register a single Replacement String at submission time: a pre-cleared alternative to swap to if the primary goes into contention on Reveal Day. This is new in 2026 and is the cheapest way out of contention. Swap to a string nobody else applied for and pay nothing beyond the evaluation fee already due.

Administrative check and Reveal Day

After the window closes, ICANN runs an 8-week administrative check: fee verification, entity checks, formatting validation. Then comes Reveal Day, typically 9 weeks after window close, which puts it around mid-October 2026. On Reveal Day, ICANN publishes every applied-for string, every applicant's identity, every replacement string, the public portions of every application, and the initial contention-set list.

The 14 days following Reveal Day are the Replacement Period. Applicants in contention can elect their replacement string and move out of the original contention set entirely. This decision is irreversible.

Once the replacement window closes, String Confirmation Day triggers the downstream clocks. A Prioritization Draw is held within 30 days. It's a paid lottery (USD 100 per ticket) that determines processing order when queues are deep. Participation is optional, but for applicants racing to market, the draw matters.

Initial Evaluation

Initial Evaluation is not one review. It is five reviews, running concurrently, each with its own panel and its own clarifying-question window.

Background Screening checks for criminal activity, financial crimes, cybercrime, organized-crime associations, and a pattern of cybersquatting (three or more UDRP or ACPA losses, at least one in the last four years), on a 10-year lookback. Unresolved findings trigger a 21-day clarifying-question window, then a 21-day Extended Evaluation if still unresolved.

String Review has three sub-reviews. String Similarity Evaluation compares the applied-for string visually, aurally, and by meaning against existing TLDs and other applications in the round. Geographic Names Review verifies any government endorsement letters for strings on ICANN's geographic list. DNS Stability Review checks the string against reserved names, blocked names, and new 2026 name-collision criteria (based on the NCAP Study 2 recommendations implemented per a September 2024 board resolution).

Technical Review is the RSP Review, the registry-service-provider stack evaluation. Applicants who named a pre-evaluated RSP sail through. Those self-evaluating face the full RSP Handbook.

Financial and Operational Evaluation scores the applicant against one of four profile classes: Government, existing Registry Operator, Top-25 public, or Standard. Standard applicants submit three years of audited, reviewed, or compiled financial statements, CEO/CFO self-certification of long-term funding, a three-year Domains-Under-Management forecast, a DNS abuse plan, and a security policy. Minimum cash on hand: USD 50,000 plus 25% of the application fee, capped at USD 300,000.

Registry Services Review evaluates each service the applicant proposes to offer (EPP extensions, RDAP extensions, specialized features) for DNS, security, or stability concerns.

All five reviews run in parallel over roughly 180 days. Extended Evaluation is a cure mechanism, not a separate stage. Failed panels get a 15-day window to request it, and 21 days for the panel to review supplementary materials. If Extended Evaluation fails, the application is out, with no further remediation this round.

Objections and appeals

The Objection Window runs for 104 days from String Confirmation Day, in parallel to Initial Evaluation. Four grounds exist, each with its own eligible filer profile and dispute-resolution provider.

String Confusion Objection. Filed by existing gTLD operators, ccTLD operators or Significantly Interested Parties, or other applicants in this round not already in the same contention set. Handled by the World Intellectual Property Organization (WIPO). Prevailing on this objection puts both strings into contention.

Legal Rights Objection. Filed by trademark or intellectual-property rights holders, or intergovernmental organizations meeting .INT criteria. Also WIPO. Prevailing makes the targeted application ineligible to proceed.

Limited Public Interest Objection. Anyone may file. Handled by the International Chamber of Commerce (ICC). Prevailing kills the target.

Community Objection. Filed by established institutions with an ongoing relationship to a clearly delineated community. ICC. Prevailing kills the target.

Every objection requires a filing fee plus advance payment of panel costs. The prevailing party is refunded; the losing party eats it. Filing fees ran USD 5,000 to USD 13,000 in 2012 depending on objection type. The 2026 rates are set by the DRSPs (WIPO and ICC) and the final 2026 schedules are not yet published.

Appeals are new in 2026. A party adverse to a panel determination has 15 days to file a Notice of Appeal, then 15 more days to file the appeal itself, under a clearly-erroneous review standard, with a 5,000-word limit. That is a genuine improvement over 2012, when objection determinations were effectively final.

The contention decision: the hinge

This is where the 2026 rules differ most from 2012. If two or more applicants are applying for the same string (or for visually-similar strings that cannot coexist), they form a contention set. The 2026 Applicant Guidebook, Section 5.2.2, allows exactly two methods to resolve a contention set: Community Priority Evaluation and ICANN Auction of Last Resort. Section 5.2.3 is categorical:

Any other resolution methods, such as private auctions or joint ventures, or any other arrangement designed to resolve contention privately, are strictly prohibited.

In the 2012 round, 218 of 234 contention sets were resolved by private auction. The mechanism worked like this. Applicants in a contention set agreed to an auction (usually ascending-clock, second-price) run by a third-party auctioneer. The winning bidder paid, but the money went to the losing applicants, split among them. Losing was profitable. That created a side-industry of "greenmail" applications filed purely to collect payoffs from more-serious applicants. Entire portfolios at Donuts, Uniregistry, Rightside, and Minds + Machines were partially funded by losing private auctions.

In 2026, that is gone. Communication between contention-set applicants is now explicitly prohibited under threat of disqualification. Every contention that reaches the resolution stage goes either to CPE or to an ICANN auction where the money flows to the ICANN Grant Program.

This is a large structural shift toward community applicants. The 2012 regime let well-capitalized operators effectively buy out community applicants for the price of a payoff. The 2026 regime makes contention binary: win CPE or win the auction, no side deals.

The CPE election window

Section 5.4.3 of the Applicant Guidebook defines the step where community applicants opt in or out of CPE. Trigger conditions: all applications in the contention set have completed string evaluation, all objections and appeals have resolved, all open challenges have closed. When that is true, ICANN sends a notification to every Community Application in the set. The applicant then has 30 days to pay the CPE election fee (USD 50,000 to USD 80,000) and opt in, or decline and drop into the ICANN auction queue along with everyone else in the set.

Community Application designation is made at original submission. An applicant cannot retroactively convert a standard application to a Community Application at the 30-day election window. The in-or-out decision at the window is binary. Which is why the Specification 12 community registration policies and endorsement letters have to be locked down and application-ready by 12 August 2026. There is no fix-it-later.

Community Priority Evaluation

Community Priority Evaluation is the mechanism that makes community-backed gTLDs possible. The rule, in one sentence: a community applicant that scores at least 12 out of 16 points on a four-criterion scorecard wins the string outright, extinguishing every other applicant in the contention set.

The scorecard has four criteria, each with sub-criteria and a point budget:

Criterion2012 points2026 pointsWhat it measures
1. Community Establishment46Organization, engagement, awareness, established presence, longevity
2. Nexus44Does the string match the community?
3. Registration Policies42Are registration rules community-restricted and purpose-aligned?
4. Community Endorsement44Do the organizations representing the community support the bid?
Total1616
To prevail14 (87.5%)12 (75%)

The headline changes from 2012 to 2026: Community Establishment grew from 4 to 6 points, Registration Policies shrank from 4 to 2, and the prevailing threshold dropped from 14 to 12. The structure tells applicants to invest in proving the community is real. Registration policies are now mostly a gate rather than a differentiator.

Criterion 1: Community Establishment (6 points)

Split across five sub-criteria: Organization (2), Engagement (1), Awareness (1), Established Presence (1), Longevity (1). The applicant has to show a single organization representing the whole community (or a small set of organizations covering every segment), documented activity over the prior two years, members who know about each other and the community as defined, external recognition that the community existed before the application window opened, and evidence of enduring intent.

What scored 4/4 in 2012: .osaka. The Osaka Prefectural Government itself applied. That covered everything the criterion cares about: a defined territorial community, a legitimate organizing body, centuries of institutional longevity.

What scored 0/4: .music's DotMusic application. The panel found the 42 supporting organizations were each legitimate, but had never acted together as "the music community." Amateur-musician clubs had no demonstrable cohesion with rights-management bodies. The panel applied the Guidebook's false-positive test (community construed to grab a generic word) and ruled accordingly.

Criterion 2: Nexus (4 points)

Single sub-criterion. Does the string match the community?

  • 4 points: full match. String is the community name or a well-known alternative.
  • 2 points: strong match, but the string has other in-use meanings the public might associate with it.
  • 1 point: partial match, with other common meanings.
  • 0 points: weak or no match.

This is where the guillotine usually falls. .gay scored 0/4 here for two reasons. The string evokes a community much larger than dotgay LLC's defined members (roughly 70 million worldwide versus 7 million registered with authenticating partners). And the defined community included bisexual, transgender, intersex, and heterosexual "ally" members whom the word "gay" does not identify. Either direction of mismatch zeroes the criterion.

Criterion 3: Registration Policies (2 points)

Two sub-criteria: Eligibility (1) and Name Selection (1). Does the registry restrict registration to community members? Are name-selection rules consistent with the community purpose?

This criterion was worth 4 points in 2012 and was split into four sub-criteria including Content & Use and Enforcement. The 2026 rubric moves those checks into a separate Registry Commitments Evaluation that runs in parallel. CPE now scores only the two most load-bearing policy elements.

Criterion 4: Community Endorsement (4 points)

Four-tier scoring:

  • 4 points: majority support, no relevant opposition.
  • 3 points: majority support, minority opposition.
  • 2 points: majority support, also significant opposition.
  • 0 points: no majority support.

The Guidebook requires every letter of support or opposition to clearly state its position, demonstrate the signer knows which string is being requested, be independently verifiable, and describe the process and rationale used in arriving at the expression. Template letters or drive-by endorsements do not count. Opposition from any relevant 501(c)(3)-scale organization drops the score. Only negligible-size or clearly obstructive opposition can be dismissed.

The panel

ICANN selected Analysys Mason Limited as its 2026 CPE provider on 18 March 2026. Analysys Mason is a global management-consulting firm with more than 400 consultants across 17 offices, replacing the Economist Intelligence Unit that ran CPE in 2012. The switch is deliberate. The 2017 FTI Consulting review of the 2012-round CPE process surfaced inconsistencies in EIU's research practices that drove multiple Reconsideration Requests and Independent Review Process filings.

The 2026 panel may:

  • conduct limited independent research, specifically to fact-check information the applicant provided
  • issue CPE Clarifying Questions to the applicant or to parties who filed opposition letters (21 days to respond)
  • consult community experts for specialized or localized communities, with disclosure to the applicant
  • issue a scoring report against all four criteria

The applicant has 21 days after the scoring report to file an Evaluation Challenge on factual, procedural, or system-error grounds. A different set of panelists reviews, when practicable. No fee. That is the reconsideration mechanism.

Total CPE duration is estimated at 180 days.

Outcomes

  • 0 passers (no community applicant scores ≥12): the entire contention set goes to ICANN Auction.
  • 1 passer: that applicant wins the contention set; all other applicants in the set become ineligible.
  • 2+ passers: the passing Community applications go to an ICANN Auction between themselves; non-community applicants in the set become ineligible.

Who has won CPE

Five community applications prevailed in the 2012 round, and all five operate today under Specification 12 community registry agreements:

StringScoreOperator
.osaka15/16Interlink Co. Ltd. (Japan)
.radio14/16European Broadcasting Union
.hotel15/16HOTEL Top-Level-Domain S.a.r.l.
.eco14/16Big Room Inc.
.spa14/16Asia Spa and Wellness Promotion Council

.hotel came with an asterisk. Years of subsequent Independent Review Processes, plus a portal data-breach controversy. The other four are clean examples of the path working as designed.

The live controversy

In July 2025, Kathy Kleiman, co-founder of ICANN's Noncommercial Users Constituency and a long-standing figure in internet governance, published an open letter on CircleID accusing the SubPro Implementation Review Team of quietly rewriting rather than implementing CPE rules. Her specific objections:

  1. Limited independent research. Panels can now only fact-check information the applicant provided, not conduct broader research into competing communities. Kleiman argues this was originally an explicit SubPro Recommendation 34.21 protection that has been narrowed.
  2. "Majority" redefined. Majority is now measured based on the size of the community as the applicant defines it, rather than the broader community that shares the name. Kleiman says this inverts SubPro Implementation Guidance 34.20.
  3. Misappropriation risk. Kleiman's central example: the new rubric could let a self-identified "Cherokee car enthusiasts" group score higher on Community Establishment than the Cherokee Nation itself, if the small group demonstrates internal organization and the Nation does not submit formally structured opposition.

No formal ICANN or IRT public response has been published. Public comment on the final draft AGB closed 23 July 2025, two days after the letter. The final AGB (v1-2025.12.16, 16 December 2025) retains the structure Kleiman criticized. Applicants should assume these provisions are live. Advocates should engage directly with the Analysys Mason panel as individual cases arise.

ICANN Auction of Last Resort

When CPE does not produce a single winner (no community applicant in the set, no community applicant elects CPE, or no community applicant prevails), the contention goes to an ICANN Auction.

The mechanics are ascending-clock, second-price. The auctioneer announces rising prices in timed rounds. Bidders indicate whether they will stay in at the new price. As the price climbs, participants drop out. The auction ends when only one bidder remains above the clock. The winner pays the price at which the second-to-last bidder exited, not the final clock price, and that payment goes to ICANN.

Historical 2012-round ICANN auction outcomes ranged widely. Examples:

StringWinnerPriceDate
.buyAmazonUSD 4,588,888Sep 2014
.techDot Tech LLCUSD 6,760,000Sep 2014
.appGoogleUSD 25,001,000Feb 2015
.shopGMO RegistryUSD 41,500,000Jan 2016
.webNu Dot CoUSD 135,000,000Jul 2016

The .web saga

.web is the cautionary tale of the 2012 round. Nu Dot Co bid USD 135 million in July 2016, more than triple the prior record. Within days, another applicant (Ruby Glen, a Donuts entity) sued, alleging Nu Dot Co had an undisclosed backer. The U.S. DOJ Antitrust Division opened an investigation in February 2017, closed it without action in January 2018, and Afilias filed an Independent Review Process petition in November 2018 arguing the bid should be voided. The IRP panel ruled in May 2021 that ICANN had failed to determine whether the arrangement complied with program rules, and ordered the ICANN Board to decide the question. A subsequent panel admonished Afilias for dragging the process out. The Board ruled in May 2023 that no rules were violated and processing could resume.

.web is still not delegated. Nearly a decade after the auction, the string has no live registry. The episode showed how an undisclosed-principal bid can leave a contested string stuck in limbo for years while disputes run their course. Combined with the broader portfolio-gaming dynamics of private auctions, that is the single biggest reason the 2026 rules were tightened.

Where the money goes

ICANN auction proceeds flow into a segregated fund, separate from operations. As of 30 June 2023 the balance was USD 217 million. A Cross-Community Working Group spent years debating how to spend it. The ICANN Grant Program launched its first cycle in March 2024 with USD 10 million available and grants of USD 50,000 to USD 500,000. The first cohort, 23 projects chosen from 247 applications, was announced 29 May 2025. The program is ongoing.

ASP-qualified applicants receive bid credits in auctions, reducing the winning-bid-to-cash-out ratio. That partially offsets the losing-proceeds-to-ICANN disadvantage that small applicants face against well-funded rivals.

Contract and Pre-Delegation Testing

Winners of Initial Evaluation plus contention resolution execute the 2026 Base Registry Agreement (Board-approved 12 March 2026) within 90 days of invitation to contract. Applicants must reconfirm their application statements remain accurate. Modifications to the Base RA are allowed only in extraordinary circumstances.

Specification 12 is appended for Community Application contracts. It locks in the Community Registration Policies (eligibility and name-selection rules) that were evaluated during Registry Commitments Evaluation. Spec 12 is what makes community-by-contract real. Post-delegation, the registry must enforce these policies as a contractual obligation, subject to ICANN compliance audit. Specification 13 applies for .Brand TLDs (exclusive use by a single trademark holder). Specification 14 is new in 2026 and covers variant TLDs.

Pre-Delegation Testing (PDT) verifies technical readiness: DNS, DNSSEC, EPP, RDAP, data escrow, Whois/RDAP service, IDN tables where applicable. PDT is run by ICANN's selected vendor. After PDT passes, ICANN runs a final administrative review, the Registry Operator names a Delegation Point of Contact, ICANN issues a Root Zone Management System token, and the three Root Zone Partners (ICANN, NTIA, Verisign) execute the delegation. Typical timing from PDT pass to delegation is about 5 business days.

Launch: Sunrise, Landrush, GA

Once delegated, every 2026 gTLD must follow the Rights Protection Mechanisms sequence enforced by the Base Registry Agreement:

  • Sunrise Period (mandatory, at least 30 days): registrations limited to holders of a trademark validated in the ICANN Trademark Clearinghouse with a Signed Mark Data file.
  • Landrush (optional): some registries run a premium-priced open window between Sunrise and General Availability.
  • General Availability: standard-price registration via accredited registrars.
  • Trademark Claims Service (mandatory, 90 days from GA): notifies would-be registrants that a label matches a TMCH record, and notifies the trademark holder of any matching registration. Cannot overlap Sunrise.

Post-launch, the Registry Operator has a one-year operational requirement and ongoing Registry Agreement obligations: uptime SLAs, abuse reporting, data escrow, compliance audits.

Timeline summary

PathTotal duration (application to delegation)
Uncontested14.5 to 19.5 months (range depends on round volume)
Contested, CPE prevails~21 to 26 months
Contested, CPE fails → auction~22 to 27 months
Contested, no CPE → auction~18 to 23 months

Applications filed August 2026 reach delegation in late 2027 at the earliest, and mid-2028 for contested outcomes.

Fees summary

Line item2026 amountNotes
Base application feeUSD 227,000Covers all standard evaluations
ASP reduction75–85% off baseEffective base USD 34,050 – USD 56,750
.Brand eligibility (Spec 13)USD 500Conditional
Registry Commitments EvaluationUSD 15,000Conditional, covers all commitments
Geographic Names Reviewup to USD 12,000If applicable
Name Collision MitigationUSD 100,000 – USD 150,000If high-risk
CPE electionUSD 50,000 – USD 80,000Only if community applicant elects CPE
String Confusion / Legal Rights objectionSet by WIPO2012 rates USD 5,000 – USD 13,000 + panel
LPI / Community objectionSet by ICCSimilar structure
Annual fixed registry feeUSD 25,000 – USD 25,800/yrPost-delegation
Per-transaction ICANN feeUSD 0.25 per domain-yearAbove 50,000 names/quarter
Continued Operations Instrumentup to USD 300,000 face valueLetter of credit or escrow
Refund, withdraw day 1–10 post-SCD65%~USD 147,550
Refund, withdraw pre-evaluation35%~USD 79,450
Refund, withdraw mid-evaluation20%~USD 45,400
Refund, post-contract0%

What changed from 2012

  1. Private auctions prohibited (Section 5.2.3). Losing applicants no longer get paid to walk away. Contention is binary: CPE or ICANN auction.
  2. ASP expanded. Fee reduction raised to 75–85%, pro-bono services added, bid credits included.
  3. Predictability Framework. A structured mechanism for handling mid-round emergent issues, replacing 2012's ad-hoc approaches.
  4. RSP pre-evaluation. Technical vendors pre-qualify separately, speeding individual applicant reviews.
  5. CPE rubric restructured. Community Establishment up to 6 points (from 4), Registration Policies down to 2 (from 4). Prevailing threshold dropped from 14 to 12.
  6. Replacement String. Applicants can swap pre-declared alternatives during a 14-day window after Reveal Day.
  7. Name Collision Framework. Rebuilt per NCAP Study 2 recommendations: temporary delegation plus analytic data, rather than 2012's Controlled Interruption.
  8. Variant TLDs formalized. Specification 14 and AGB Section 7.6.
  9. Appeal mechanism on objections. 15-day notice plus 15-day filing, clearly-erroneous standard. A real appeal path that did not exist in 2012.

What it means for .agent

For a community applicant like the one forming around .agent, the 2026 rules are the friendliest ICANN has ever produced. The private-auction loophole that bled communities dry in 2012 is closed. The CPE threshold is lower (12/16 instead of 14/16). The Applicant Support Program exists and has been funded. Specification 12 is a real, enforceable community contract, not a marketing commitment.

The catches are equally clear. The base fee is USD 227,000 per string. Specification 12 registration policies have to be application-ready by 12 August 2026. Not sketched out, not in-progress, but ready for a skeptical panel to read cold. Endorsement letters from the organizations expected to support a community-governed agent namespace must be in hand. The community itself must be documented: registered organizations, recorded activity over the prior two years, a clear definition of members, a clear story about longevity.

Everything the community does between now and August is application prep. Every member who joins adds to Community Establishment and Endorsement. Every policy draft firms up what Spec 12 will eventually say. Every organizational partner who signs on is a letter that could go on file.

The rules reward organization. Not in the metaphor sense. Literally, in the scorecard.

Further reading

Primary sources:

Community-backed context:

Independent reporting:

— Balazs