Mandatory SIM Card Registrations – Addressing the Challenges
by Mereseini Tuivuniwai
The National Information & Communications Technology Authority (NICTA) of Papua New Guinea just recently extended the deadline of Mandatory SIM Card registration with the deactivation commencing on 28 January, 2018. Whilst there has been mad rush from the public to get SIMs registered, most may not realize that the mandatory process was in effect as of July 23, 2016.
As per SIM Card Registration Regulation 2016 (Statutory Instrument No.7 of 2016) as published in National Gazette No. G228 dated April 22, 2016; the objective of the regulation is to provide a regulatory framework for the registration of all SIM card users and for the control, administration and management of the Subscriber Information Database. The regulation applies to all licenses and all persons who use a SIM card in PNG but shall not extend to users of SIM cards issues by foreign licenses.
First of all, NICTA must be commended for taking this step as PNG joins major countries around the world with this mandatory policy. However, like all policies there are always some downsides to it. Given the significant costs involved in implementing the registration process, maximising the benefits that can be derived from the exercise is very important.
Prepaid SIM card registration is currently mandated in around 90 countries and requires consumers to provide proof of identification in order to activate and use a mobile SIM card. A number of governments adopt this policy as part of efforts to help mitigate security concerns and to address criminal and anti-social behaviour. To date, there has been no empirical evidence that mandatory SIM registration directly leads to a reduction in crime. However, where the exercise is implemented effectively by taking into account local market circumstances, for example the ability of mobile operators to verify customers’ identity documents, SIM registration can enable many consumers to access value added mobile and digital services that would otherwise be unavailable to them as unregistered users. However, if the registration requirements are disproportionate to the specific market, the mandatory policy may unintentionally exclude vulnerable and socially disadvantaged consumers.
PNG is usually depicted as a land with high mountains fast flowing rivers and scattered islands making government services delivery in most part of the country a main challenge. Imagine the daunting task of registering a segment of the more than 8 million Papua New Guineans who live in one of the most diverse countries in the world with 848 different languages and physical terrains that has posed enormous difficulties in building transportation infrastructure.
Following SIM registration requirements in Zimbabwe, the two leading operators lost two million subscribers. In South Africa, MTN lost nearly a million subscriptions and growth for the industry slowed considerably afterward. In Kenya, more than 1.2 million SIM cards were shut off because they were not registered by the deadline. While some of these were unused accounts, many more were people who could not – often through no fault of their own – register their SIM cards.
‘Proof of ID’ requirements
There are various challenges but proof of ID requirements is anticipated as a major one for PNG. Like most countries, ‘Proof of ID’ requirements and this varies significantly across countries. The types of customer identity documents that mobile operators are asked to check as part of mandatory SIM registration processes vary – from government-issued identity cards and passports, to letters from the ‘village chief’ certifying the identity of the person being registered. However, in a number of countries, consumers who lack any official proof of ID risk being disconnected from mobile communications altogether. Globally, current estimates suggest that there are 1.5 billion people around the world who do not have any form of identity and would therefore be unable to register a mobile SIM in their own name, where SIM registration is mandated. Consequently (and ironically), the same policy that aims to reduce crime may be taking away those consumers’ means to report a crime or call emergency services.
More fundamentally, are those that lack formal identity documents, either because they never received them or have lost them over the years.
However, herein lies an opportunity. With the increasing importance of citizens having a secure digital identity and where there are issues with the availability of official identity documents, there may be a role for operators to support the government in the creation of a unique identity that can be authenticated and used for a variety of mobile and non-mobile services. This will, in part, help individuals who lack formal identity documents to access communication services but also potentially e-Government and other value added services that could deliver incremental value – not just to people’s lives but also to economic growth, through the uptake of new services via the mobile platform and the creation of jobs, etc.
Clearly, while mobile operators should not replace the role of the state as the provider of a legal identity, they are uniquely placed to help underserved members of society benefit from services that would otherwise be unavailable to them as unregistered users.
Increasing the opportunity to use mobile registration data for value-added services also increases the incentive to clean and maintain accurate data. This benefits consumers, governments and operators, to the extent that the registration requirements are proportional, reasonable from a cost perspective and any risks of social exclusion or to consumers’ privacy are mitigated.
In an ideal world the only SIMs that would be deactivated and barred from accessing mobile networks would be those that customers deliberately had deactivated, perhaps because they decided to keep a different SIM. In reality, this is rarely the case with large numbers of customers’ SIMs deactivated, only to reactivate the service after they have been excluded. Whilst the security priority may be to exclude unregistered SIMs, there is a need to balance this priority against the financial and social impact of excluding large numbers of people.
Setting reasonable timescales for registration and potentially limiting services for customers that haven’t registered are both approaches that can mitigate the risk of deactivation. To encourage registration a number of markets block some aspect of the service for a period before deactivating it completely. Nigeria, for example, blocked outgoing calls for three months prior to deactivation.
The people most at risk of deactivation are also the most vulnerable and socially disadvantaged citizens, especially those in rural areas. These citizens are often the same citizens that lack official ID papers and have the least access to locations that allow them to register. If implementation timescales are set too aggressively it is this community most likely to suffer.
Deactivation may also affect users who have mobile money wallets as deactivation to their accounts will mean deactivation to their mobile wallet accounts.
Whilst financial considerations rarely have a bearing on decisions related to mandatory SIM registration there is potentially significant impact on operator revenues and on tax revenues from deactivating large numbers of people who have failed to register. There is also significant evidence that the economic and social costs of exclusion are high. There is an impact on GDP, an impact on investment and all of the negative effects of digital exclusion for citizens. The registration process should look to encourage active users to register and to use mobile services; they should not exclude citizens, especially those who fail to register unintentionally.
Social and Economic Impact
The potential positive contribution of mobile registration should be considered as well as any role it may play for addressing security concerns. When implemented effectively, and assuming the appropriate consumer safeguards are in place, mobile registration can facilitate financial access or financial inclusion, help National ID registration and enable access to government services. Whilst mobile services deliver social and economic benefits on their own, enabling other services delivers incremental value. In 2015 the indirect benefits of mobile on the wider economy through general economic development and productivity improvement was 2.7% GDP growth, which globally equated to $2.025 trillion. Whilst addressing security and crime is the main reason governments give for the introduction of mandatory SIM registration requirements, the opportunity to add social and economic value should not be ignored. For many customers this can add significant value and it can also help other government departments achieve their public policy objectives and goals. Given the significant costs involved in implementing the registration process, maximising the benefits that can be derived from the exercise is very important.
During this process, it is critical that stakeholders consider the following:
- Set registration deadlines that are realistic and reflect local market circumstances
• Ensure registration requirements are clear and unambiguous
• Encourage the storage of electronic (rather than paper-based) records
• Encourage the registered ID to be used for other value-added mobile and digital services
• Contribute to consumer awareness campaigns and to mobile operators’ operational costs
In the coming months, we hope that the SIM registration policy requirements are proportional and realistic, enabling – rather than inhibiting – services that can improve Papua New Guinean people’s lives and build a more inclusive society.
Mereseini Tuivuniwai is the Manager – Communications & Stakeholder Mobilisation with the Centre for Excellence in Financial Inclusion (CEFI)