And it is not going to get easier for sure.
At the moment we run a validation process, this process also makes sure that there is a registration contract between Realtime Register, Esnic and the registrant, as required by the registry. An easy process for you as a reseller.
However, with the GDPR and some local laws in Spain which go beyond the original purpose of domain name registrations, the contractual requirements for the registrant and reseller increased in such a manner that we are no longer in a position to create such contracts for our resellers in a one size fits all solution.
As a result, we pass this obligation to our resellers once more for .ES domain names to ensure maximum flexibility for your registration processes towards your customers.
However, the changes made by Esnic require that you obtain explicit consent from your customer/registrant for several obligations. Below is a sample provided by Esnic.
The template is for reference purposes only. In addition to this registrants will need to enter into a registration contract with Esnic, which is located here.
We urge our resellers to create registration agreements as suggested by Esnic. Not having a registration contract regarding .ES is not an option as Esnic processes personal data in a different manner compared to other EU registries and beyond the primary purpose of domain name registrations.
We will update this post as soon we are getting close to turn off validation.