One of our customers referred us to this thread, so let me please add how things work just to avoid confusion within the community:
Please note that what I write below applies to registries/TLDs that are overseen and regulated by ICANN. Many ccTLDs have their own rules, but the information below applies to registries/registrars that must comply with ICANN rules.
The 60-day lock from prior transfer between registrars (inter-registrar) is enforced solely by the losing registrar. As had been previously noted, registrars are permitted specific reasons in which they may reject an outbound transfer request to a different registrar. Among the list of allowable rejection reasons is that it is within 60-days of prior transfer. In our experience, all registrars enforce this rule for several reasons. For us, I can say that the major reason is related to fraud prevention, although there are others. In some situations, such as a sale from a known Seller within our system to a Buyer wanting to transfer to a different registrar, we are happy to bypass the rejection, and have done so many times, so I can assure you all that registrars have this ability. To further illustrate, here is how a transfer between registrars works chronologically:
- The gaining registrar submits a transfer request to the registry. Along with the domain name to be transferred, the gaining registrar also must send the correct EPP auth code.
- The registry then "notifies" the losing registrar of the transfer request.
- The losing registrar can then do any of the following:
- Do nothing. If nothing is done, the transfer to the gaining registrar completes when the registry automatically releases it after 5-6 days.
- Reject the transfer for any of the reasons permitted by ICANN within 5 days. Again, this includes the right to reject based upon prior transfer within 60 days. This list of allowable rejection reasons also includes the new rule governing intra-registrar transfers (most commonly a change of Registrant) within 60 days implemented in December 2016.
- Explicitly accept the transfer. This is technically referred to as an "ACK" in EPP land. If the losing registrar ACKs the transfer, it completes immediately. This is what you see from registrars like us that permit expediting outgoing transfers without waiting the 5-6 days for automatic registry release.
The 60-day lock from the date of registration is enforced by registries, and is not something registrars can bypass.
Hope this helps as there is a lot of information out there that is either inaccurate, confusing or incomplete, and different registrars have different rules thereby adding to the confusion since most people on this forum keep domains with multiple registrars and have therefore experienced different things.
