SECOND MEASUREMENT SM-026
The domain-dispute rules give the provider five days to appoint a panelist once the response is in or its deadline passes. In 2025 and 2026 WIPO took longer in 6,095 of 7,468 cases, median 8 days; the Forum, under the same rule, in 31 of 4,791
The claim: Domain disputes: ICANN’s rules give the provider five days to appoint a panelist; WIPO took longer in 6,095 of 7,468 cases in 2025–26, the Forum in 31 of 4,791
What we found: WIPO appointed more than five days after the response or its deadline in 81.6% of single-panelist cases, median 8 days; the Forum 0.6%, median 1. Deadline to decision: WIPO median 22 days, the Forum 2. WIPO’s $4,000 priority service (March 2026) left the share unchanged.
Status: Published 24 Oct; checked twice against the exhibits before publication; questions to WIPO’s Arbitration and Mediation Center not yet sent
When a company says someone registered a web domain in bad faith to trade on its name, it can file a complaint under the Uniform Domain Name Dispute Resolution Policy (UDRP), and a provider appoints an independent panelist to decide it. ICANN’s rules for every provider say the panelist is to be appointed “within five (5) calendar days” of the response arriving or its deadline passing. WIPO’s Arbitration and Mediation Center handles most of these cases. We read every WIPO decision in English for its 2025 and 2026 generic-domain cases: in 6,095 of 7,468 single-panelist cases (81.6%) the panelist was appointed more than five days after that point, median 8 days. The Forum, the second-largest provider, working under the same rule, took longer in 31 of 4,791 (0.6%), median 1 day, and 13 of those 31 are typing slips in the decisions or our reading errors. From the response deadline (or an earlier response) to the decision itself: WIPO median 22 days, the Forum 2.
- ICANN’s Rules for Uniform Domain Name Dispute Resolution Policy, paragraph 6(b): “the Provider shall appoint, within five (5) calendar days following receipt of the response by the Provider, or the lapse of the time period for the submission thereof, a single Panelist from its list of panelists.” The rules let the provider extend the response deadline (paragraphs 5(b) and 5(e)) and suspend a case for settlement (17(a)); none lets it extend the five days (once appointed, the panel itself may extend periods “in exceptional cases”, 10(c)). Paragraph 15(b): “In the absence of exceptional circumstances, the Panel shall forward its decision … within fourteen (14) days of its appointment.”1
- WIPO decisions state the response due date and any extension, when a response was filed, and when the panelist was appointed. We read case numbers D2025-0001 to D2025-5700 and D2026-0001 to D2026-4300 (the last 2025 decision is D2025-5461): 8,020 decisions. Counted: 7,468 single-panelist decisions in English with no suspension and both dates readable. 6,095 appointed more than five days after the response arrived or its deadline passed (81.6%); median 8 days; 2,498 more than ten days; 289 more than twenty.
- The Forum (formerly the National Arbitration Forum), same rule: 31 of 4,791 (0.6%), median 1 day. In 4,189 of its 4,442 cases with no response before the deadline, the panelist was appointed on the deadline day or the next. Reading each of the 31: 9 are date typos in the decision, 4 more are reading errors or an extension or stay we missed, 5 are late only because the response arrived early, 12 look genuine and 1 is unclear.
- From the response deadline (or an earlier response) to the decision: WIPO median 22 days, 4,856 of 7,437 more than the 19 days that 6(b) and 15(b) together allow (65.3%); the Forum median 2 days, 18 of 4,602. This measure does not depend on what each provider records as the appointment.
- In most WIPO cases there is no response. WIPO first notifies the parties of the respondent’s default, a median 2 days after the deadline, then appoints a median 6 days after that. Counted from its own default notice instead of the deadline, 3,275 of 5,819 appointments (56.3%) still came more than five days later.
- On 9 March 2026 WIPO announced a paid priority service: “Like overnight shipping or airport priority queues … we are rolling out a new priority service to commit to decision delivery in one-month from start to finish”, at $4,000 for one to five domains ($1,000 to WIPO, $3,000 to the panel) against $1,500 standard ($500 and $1,000).2 The share did not change: 81.9% appointed after five days from January 2025 to the announcement, 81.1% since.
Disclosure: Markovian Protocol holds no financial position in any domain registrar, registry or dispute provider, has never filed a UDRP complaint, was paid by no one for this work, and showed it to no one before publication. How we work.
Two providers, one rule
| WIPO | Forum | |
|---|---|---|
| Single-panelist decisions counted | 7,468 | 4,791 |
| Appointed more than 5 days after the response or its deadline | 6,095 (81.6%) | 31 (0.6%) |
| Median days | 8 | 1 |
| Middle half | 6–12 | 1–1 |
| More than 10 days | 2,498 | 20 |
| Clock from the deadline: late / counted | 5,704 / 7,003 | 22 / 4,442 |
| Clock from the response, on or before the deadline: late / counted | 391 / 465 | 9 / 349 |
| Decision more than 14 days after appointment | 918 of 7,437 (12.3%) | 73 of 4,602 (1.6%) |
| Median days, appointment to decision | 14 | 1 |
| Median days, deadline or response to decision | 22 | 2 |
| More than 19 days, deadline or response to decision | 4,856 (65.3%) | 18 (0.4%) |
WIPO: generic-domain (“D”) case numbers D2025-0001 to D2025-5700 and D2026-0001 to D2026-4300, read from wipo.int on 24 October 2026; 8,020 had a published decision (the rest were withdrawn, terminated or are pending; many 2026 numbers above 3500 are still pending, which leaves the slower recent cases out). Country-code cases (DCO, DIO and others) are not included. Not counted: 251 decisions with no readable procedural history (250 of them in other languages), 104 three-member panels (a different rule, 6(e)), 150 suspended, 28 with no appointment date we could read, 19 with no due date. Forum: every UDRP decision dated 1 January 2025 to 24 October 2026 in the Forum’s own decision search, 4,943, one of which is not online; “Cancelled” there is the outcome (the domain was cancelled), and those cases are counted. Not counted: 82 three-member panels, 61 with no appointment date read, 8 with no deadline read. The Forum is selected by decision date and WIPO by case number, so the periods overlap but are not identical. Start, for both: the earlier of the response’s receipt and the response deadline after any extension, as 6(b) reads. Counted instead from the later of the two, which gives an early response its full period: WIPO 5,999 of 7,468 late (80.3%), the Forum 24.
Where WIPO’s days go
In the 5,819 WIPO cases where we read a dated default notice, WIPO notified the default a median 2 days after the deadline (2,865 within a day) and appointed a median 6 days after that. Only 2,544 appointments came within five days of WIPO’s own notice. The Forum’s decisions record the same default notice without a date and appoint within a day of the deadline.
| WIPO, by when the five days began | Cases | Over 5 days | Median |
|---|---|---|---|
| 2025, January to June | 1,710 | 83.0% | 9 |
| 2025, July to December | 2,309 | 83.2% | 8 |
| 2026, 1 January to 8 March | 769 | 75.6% | 8 |
| 2026, 9 March on (after the priority service) | 2,679 | 81.1% | 8 |
Month by month for both providers is in summary_2026-10-24.json. WIPO’s monthly share over five days ranged from 71% to 91% in every month with more than 100 cases; the Forum’s from 0% to 2.2%.
Who waits
The complainant is usually a company trying to recover a domain that copies its name; in about 94% of the WIPO cases we counted the clock started at the deadline, with no response by then. The domain stays with the registrant until the decision, and UDRP Policy paragraph 4(k) then gives ten business days before a transfer.3 At the Forum, a case with no response reaches a panelist within a day of the deadline and a decision about two days after it; at WIPO, a panelist a median eight days after and a decision about three weeks after. WIPO’s new service offers a one-month case for $2,500 more, “decided by a special roster of panelists”;2 a practitioner who used it reported that the panelist was appointed “on the same date that it notified the parties of the respondent’s default”, and that in his standard cases “the panel appointment process took anywhere from three to eight days”.3
How this ends
WIPO can close it by appointing within the five days the rules set for every case, as the Forum does, or by explaining what in its process the rule does not account for. ICANN, which sets the rules for all providers, can say how it reads paragraph 6(b). We rerun both censuses each quarter and print the shares here.
Our questions
Sent on 24 October to WIPO’s Arbitration and Mediation Center (domain.info@wipo.int). Answers will be printed here as written.
- Paragraph 6(b) of the Rules gives the provider five calendar days from the response or the lapse of its deadline. How does the Center read that period, and does it start from the deadline or from its notice of default?
- In 2025 and 2026 the Center appointed the panelist more than five days after that point in 6,095 of 7,468 single-panelist cases, median 8 days. What accounts for the time?
- Do expedited cases, at $4,000, appoint within the five days, and does the Center consider standard cases bound by the same five days?
Their reply, scored
| 24 Oct 2026 | Measured: both censuses read. An independent check of every number and quote against the exhibits before publication found extensions, suspensions and responses our patterns missed, Forum “Cancelled” outcomes wrongly left out, and different start rules for the two providers; all corrected, and the late shares moved by less than a point. A second check confirmed the numbers. |
| 24 Oct 2026 | Published, and the questions sent to WIPO’s Arbitration and Mediation Center. |
What we can’t be sure of
- Dates are read from each decision’s procedural history by patterns. Two independent checks read 100 WIPO and 60 Forum cases by hand: appointment and decision dates matched; a few start dates were off by a missed response or extension, none changing a late or on-time call. A response worded in a way our patterns miss makes the clock start at the deadline instead, which makes WIPO’s count lower, not higher. Typing slips in the decisions remain: 14 WIPO and 58 Forum cases come out negative (mostly a wrong year or month) and count as on time.
- Only decided cases are counted. A case withdrawn or settled before a decision never reaches a panelist.
- Suspensions reset the timetable; we leave out the 150 WIPO cases that record one. Extensions of the response deadline are used when the decision states them.
- 42 WIPO cases waited more than 30 days. Some started from an early response or had a later filing; others have nothing in the decision to explain the wait.
- We can’t tell which 2026 WIPO decisions were expedited; the decisions don’t say. Expedited cases among the 2,679 since March would pull WIPO’s share down, not up.
Run it yourself
gunzip -k exhibits/*.gz python3 parse.py exhibits/census_2025.jsonl exhibits/census_2026.jsonl > wipo_parsed.jsonl (cd forum && python3 rebuild.py ../exhibits/forum_procedural_history.jsonl ../forum_records.json) python3 analyze.py wipo_parsed.jsonl forum_records.json summary_2026-10-24.json python3 census.py 2026 4300 census_2026.jsonl # a fresh WIPO census, a few hours (cd forum && mkdir -p listing && python3 list_decisions.py && python3 fetch_all.py && python3 build_text.py) # a fresh Forum census, then rebuild.py
Standard-library Python 3 and pdftotext. Scripts and exhibits: sm-026/.
References
- ICANN, Rules for Uniform Domain Name Dispute Resolution Policy (effective 31 July 2015), paragraphs 5, 6(b), 15(b), 17. icann.org, saved copy icann_udrp_rules.html.
- WIPO Arbitration and Mediation Center, Updated WIPO UDRP Fee Schedule and NEW Services, 9 March 2026, wipo.int; and its UDRP fee schedule. Saved copies wipo_news_2026_0005.html, wipo_udrp_fees.html.
- Doug Isenberg, What I Learned When I Filed an ‘Expedited’ UDRP Complaint at WIPO, GigaLaw, 15 July 2026 (including UDRP Policy paragraph 4(k)), and A Faster Option for Resolving Domain Name Disputes Under the UDRP, 9 March 2026. Saved copies in sm-026/exhibits/.
- WIPO UDRP decisions,
wipo.int/amc/en/domains/decisions/pdf/<year>/d<year>-<nnnn>.pdf; Forum domain decisions,adrforum.com/DomainDecisions/<id>.htm, listed through the Forum’s decision search.