DFINITY Foundation

Synapse.vote (original)

ICDevs.org

CryptoIsGood

Anvil

ICPL.app

ysyms

The Accumulators’ Neuron

RawTech Venture

Paul Young

ICPMANUAL

8yeargangDAO

Isaac Valadez

Krzysztof Żelazko

Nicolas.ic

Smaug’s Neuron for Retail Investors

ICLight.io

Synapse.vote (NEW)

Taggr Network

CodeGov

Sonic AMM

Rakeoff.io

OpenChat

ELNA AI

GEEKFACTORY

ICP Hub México

ICP Hub Poland

Jerry Banfield

WaterNeuron

ICP Hub Bulgaria

Gold DAO

NeuronPool

LORIMER

B3Pay

ZenithCode

Aviate Labs

D-QUORUM

Yuku AI

CO.DELTA △

Cosmicrafts

Arthur’s Neuron (used to be cycle_dao)

Inactive (Request Removal) - The Fools' Court

$STACK

Always Rejects

John Wiegley

This motion proposes a pilot program to verify node provider independence using UBO disclosures and third-party audits.




# Background

Node providers of the ICP network can be connected—for example, an individual might also be the owner of a company acting as a node provider. There can be legitimate reasons for such arrangements, like certain data centers only accepting companies as clients or tax considerations. However, information about such connections is currently not captured or used in the protocol. Further, there is no systematic process for assessing the independence of node providers.

# Overall Goal

* Define a clear policy on what constitutes independence among node providers, using the Ultimate Beneficial Owner (UBO) concept.
* Establish a systematic process to identify and verify dependencies between node providers, using trusted third-party services.
* Treat identified linked node providers as a single entity in subnet allocations to strengthen decentralization.

# Suggested Pilot

* As discussed in the Node Provider Working Group on May 5, we propose running a pilot with a few volunteering node providers who will complete an enhanced node provider self-declaration form and undergo an audit by a recognized third-party provider.
* The enhanced self-declaration form, which includes specific questions to assess node provider independence, is provided below.
* The pilot will help test the self-declaration form and provide practical experience with the audit process. Based on the pilot’s results, we plan to submit a follow-up motion with refined questions and process improvements if needed.
* To encourage participation in the pilot, DFINITY intends to cover the audit costs for the participating node providers.

# Enhanced Node Provider Self-Declaration for the Pilot

### Introduction (New)

The Network Nervous System (NNS) is committed to the principles of decentralization to enhance the overall security and reliability of the ICP network. Moreover, node machines must not be funded or controlled by criminal entities, as these critical infrastructure components form the foundation upon which the integrity of the entire ecosystem depends. To achieve these goals, comprehensive disclosures from node providers are required. In particular, node providers are required to

* Confirm their identity
* Commit to providing the required hardware and honest operations, as specified in the ICP Network guidelines.
* Confirm lawful source of funds and source of wealth.
* Assess potential overlaps with other node providers.

As part of the governance structure, the Network Nervous System may vote to:

* Remove node providers that violate these principles or provide untruthful responses.
* Appoint legal representation to pursue such node providers.

The self-declaration form is divided into public information (shared openly on the forum and/or wiki) and private information (shared only with an assigned auditor to verify the accuracy of the public statement). By default, answers to the questionnaire are considered public unless otherwise specified.

### Identity and Compliance Declarations

* (A) Statement of Identity (as current)
  * Public Disclosure
    * Please provide the following detailed information about your entity:
      * Entity Name
      * Representative Name
      * Position within Entity
      * Entity Address and Location
      * Country (which should not be a sanctioned country)
      * Commercial register Number
  * Private Disclosure (for an auditor)
    * Provide supporting documentation (e.g., government-issued IDs, corporate records) to verify the publicly disclosed identity information.
* (B) Statement of provision of node machines (as current)
  * I hereby guarantee that I shall provide node machines in accordance with the required Hardware Configuration for running the ICP Network, as described on the ICP wiki (see Node Provider Machine Hardware Guide).
* (C) Statement of good intent (as current)
  * I guarantee to the world that I shall honestly operate the node machines I provide, and that should I behave dishonestly, for example by deliberately interfering with my node machine(s) to prevent them correctly processing ICP protocol messages, in collusion with others or alone, that I will be liable to users of the network, and to other node providers, for any damages caused.
  * I further declare I am aware that any deliberate interference with a node machine, which causes it to incorrectly process ICP protocol messages, represents a misuse of that hardware, and of any hardware it interacts with, and that in some jurisdictions, that may constitute a crime.
* (D) Confirmation of Lawful Source of Funds & Wealth (New)
  * Public Disclosure
    * We, [Legal Entity Name], confirm that the capital and operational funding used in association with this node originates from lawful sources under the laws applicable in the jurisdiction where the node provider is registered and where the data center is located. We attest that we are not using the node for illicit activities, and that the ultimate beneficial ownership structure has been disclosed truthfully.
  * Private Disclosure (for an auditor)
    * Origin of funds: Explain the origin of the funds used to establish and operate the node provider. Detail sources such as personal savings, business income, inheritance, or investments.
    * Origin of wealth: Explanation of how the entity accumulated its total wealth (e.g., ownership of a business, inheritance, sale of property).
    * Provide supporting documentation, such as bank statements, tax statements, audited financial statements, transaction histories, or notarized statements, that allows an auditor to verify the legitimacy of these funds.
* (E) Confirmation and Update Commitment (New)
  * I, [Legal Name], hereby confirm that I am authorized to sign and submit this document on behalf of the Ultimate Beneficial Owner (UBO). I further commit to updating this self-declaration in the event of any material changes, such as a change in the UBO.

### Assessment of Independence (Ultimate Beneficial Ownership or Control) (New)

* Q1: Ownership & Control
  * Public disclosure
    * Please list the Ultimate Beneficial Owners (UBOs) or persons exercising effective control of the node provider entity, along with their full legal names and countries of residence. Please include any individual who
      * Holds ≥25% direct or indirect ownership; or
      * Otherwise effectively controls the entity’s decisions (e.g., via senior management positions, board membership, a trust arrangement, or other legal agreements).
  * Private disclosure (for an auditor):
    * Provide an ownership & control structure chart, along with corporate records, allowing to verify the control structure until the top and including any intermediary. The chart should list all UBOs and any persons exercising effective control over the node provider entity.
    * Provide supporting documentation (e.g., government-issued IDs) to verify the identities of all listed UBOs and persons exercising effective control.
    * In case of a Trust structure, please confirm the identity of the beneficiaries, settlor, trustee and protector of the Trust.
* Q2: Overlap with Other Node Providers
  * Is any UBO or person exercising effective control of this node provider also a UBO or person exercising effective control of another node provider?
  * If yes, provide the legal name(s) of the other node provider(s).
* Q3: Family Ties
  * Public disclosure
    * Is any UBO or person exercising effective control of this node provider directly related (e.g., spouse, parent/child, sibling) to an UBO or person exercising effective control of another node provider?
    * If yes, specify the relationship and the node provider(s) in question.
  * Private disclosure (for an auditor)
    * Provide the according evidence.
* Q4: Corporate Structure
  * Public disclosure
    * Are there holding companies, parent companies, or subsidiary relationships that also have stakes in other node providers?
    * If yes, specify the relationship and the node provider(s) in question.
  * Private disclosure (for an auditor)
    * Provide the related ownership structure or control chart as per Q1.
* Q5: Overlap of Financing
  * Public disclosure
    * Does any other node provider, or any UBO or person exercising effective control of another node provider, provide loans or debt financing to this node provider?
    * If yes, name the legal person(s) involved.
    * Please specify the duration of the financing.
  * Private disclosure (for an auditor)
    * If the node provider utilizes debt financing, identify the lending entity.
    * Provide all relevant documentation concerning the debt.
    * If the lender is not a publicly listed bank or a well-established financial institution, provide the name of the UBO of the lending entity.



Pilot to Assess Node Provider Independence and Improve Decentralization