The Noncommercial Users Stakeholder Group (NCSG) has submitted its response to ICANN’s request for comment on Enhancing ICANN Accountability. The comments, developed initially by NCUC member ARTICLE19, were supported by and submitted on behalf of the NCSG to ICANN.

In its comments, the NCSG noted that the current Affirmation of Commitments (AoC) mechanisms

are an essential part of accountability at ICANN, but they are far from sufficient to provide strong accountability…In our view, ICANN must be made subject to external & independent oversight mechanisms in order to ensure meaningful accountability of its decisions.

Furthermore, the NCSG suggested that

the AOC should be amended to ensure that ICANN’s decisions are fully consistent with human rights standards. In this regard, ICANN should guarantee that decisions related to the global technical coordination of the DNS are made in a transparent and accountable manner and crucially, “for the protection and advancement of human rights and Internet freedoms” rather than “in the public interest”, which is a standard that lacks sufficient specificity in this context.

Finally, the NCSG stressed that the creation or improvement of strong accountability mechanisms are inextricably linked to the
IANA transition process and reiterated that

Absent the ability to openly discuss separation of policy and implementation, completing the IANA transition proposal must be contingent on first completing an acceptable proposal addressing ICANN accountability.

You can read the NCSG’s entire comment here.