Is is mandatory for an object to belong to a registrar?

[Stephane Bortzmeyer <bortzmeyer@nic.fr>]

I suspect that the question is stupid but I nevertheless would like to
clarify things in my mind.

A colleague of me objected to EPP that EPP "mandates all objects to
belong to a registrar (the creator)". Of course, this should be a
local policy: most registries do not bill for contact creation, only
for domain creation, so there is no "hard" reason to make contacts a
property of registrars. But the issue is: is it allowed with EPP?

I believe that yes. A registry can always set a
clientTransferProhibited for all objects and/or can always reply with
2306 to every <transfer> of a contact. (Wether the current EPP
implementations allow it is another matter...)

But I wanted to be sure: a registry where contacts are *not* owned by
registrars (and therefore not transferrable) can use EPP and the
current mappings, yes or no?