Mandatory Registration of Prepaid SIMs

Background

In a number of countries, customers of prepaid or pay-as-you-go services can anonymously activate their subscriber identity module (SIM) card by simply purchasing credit, as formal user registration is not required. Around 150 governments around the world1 have mandated prepaid SIM registration citing a perceived, but unproven, link between the introduction of such policies and the reduction of criminal and anti-social behaviour. Mandated prepaid SIM registration is most prevalent in Africa, where 90 per cent of UN-recognised states have such laws.

Some governments — including the Czech Republic, the United Kingdom and the United States — have decided against mandating registration of prepaid SIM users, concluding that the potential loopholes and implementation challenges outweigh the merits.

SIM registration can, however, allow many consumers to access value-added mobile and digital services that would not otherwise be available to them as unregistered users, including identity-linked services such as mobile money, e-health and e-government services.

For a SIM registration policy to lead to positive outcomes for consumers, it must be implemented in a pragmatic way that takes into account local market circumstances, such as the ability of mobile operators to verify customers’ identity documents. If the registration requirements are disproportionate to consumers’ ability to meet them in a specific market, mandating this policy may lead to implementation challenges and unforeseen consequences. For example, it could unintentionally exclude vulnerable and socially disadvantaged consumers or refugees who lack the required identity documents. It might also lead to the emergence of a black market for fraudulently registered or stolen SIM cards, based on the desire by some mobile users, including criminals, to remain anonymous.

Debate

To what extent do the benefits of mandatory prepaid SIM registration outweigh the costs and risks?
What factors should governments consider before mandating such a policy?


Industry Position

While registration of prepaid SIM card users can deliver valuable benefits to citizens, governments should not mandate it.

To date, there has been no empirical evidence that mandatory SIM registration directly leads to a reduction in crime. Where a decision to mandate the registration of prepaid SIM users has been made, we recommend that governments take into account global best practices and allow registration mechanisms that are flexible, proportionate and relevant to the specific market, including the level of official ID penetration in that market and the timing of any national identity roll-out plans.

If these conditions are met, the SIM registration exercise is more likely to be effective and lead to more accurate customer databases. Furthermore, a robust customer verification and authentication system can enable mobile operators to facilitate the creation of digital identity solutions, empowering customers to access a variety of mobile and non-mobile services.

We urge governments who are considering the introduction or revision of mandatory SIM-registration to take the following steps prior to finalising their plans:

  • Consult, collaborate and communicate with mobile operators before, during and after the implementation exercise.
  • Balance national security demands against the protection of citizens’ rights, particularly where governments mandate SIM registration for security reasons.
  • Set realistic timescales for designing, testing and implementing registration processes.
  • Provide certainty and clarity on registration requirements before any implementation.
  • Allow and/or encourage the storage of electronic records and design registration processes that are administratively ‘light’.
  • Allow and/or encourage the SIM-registered customer to access other value-added mobile and digital services.
  • Support mobile operators in the implementation of SIM-registration programmes by contributing to joint communication activities and to their operational costs.

1. GSMA Report: Access to Mobile and Proof of Identity.

Resources

GSMA report: Mandatory registration of prepaid SIM cards — Addressing challenges through best practice
GSMA White Paper: Mandatory Registration of Prepaid SIM Card Users
GSMA Report: Regulatory and Policy Trends Impacting Digital Identity and the Role of Mobile
GSMA-World Bank Green Paper: Digital Identity — Towards Shared Principles for Public and Private Sector Cooperation
London School of Economics Academic Paper: The Rise of African SIM Registration — Mobility, Identity, Surveillance & Resistance
 GSMA Mobile Connect website
Simon Fraser University Academic Paper: Privacy Rights and Prepaid Communication Services