Yes. Pursuant to Section 2.2.4 of the RPM requirements as provided by ICANN, the only way a Registry Operator can Allocate or register domain names to a third party prior to the Sunrise Period is through an Approved Launch Program or, if made available, a Qualified Launch Program. In order to offer an Approved Launch Program, a Registry Operator must apply to ICANN and have its application approved prior to offering the Approved Launch Program. For more information, please ICANN's website