Utilization of Embedded Subscriber Identity Module (e-SIM)
On April 11, 2025, the Minister of Communication and Digital issued Regulation No. 7 of 2025 on the Utilization of Embedded Subscriber Identity Module (“e-SIM”) Technology in Telecommunication Implementation (the “Regulation”).
The Regulation responds to technological innovation and the increasing ease of e-SIM utilization by telecommunications services subscribers, whether via mobile or satellite networks provided by telecommunication providers. The Regulation also aims at supporting the expansion of machine-to-machine (M2M) communication systems and Internet of Things (IoT). We set out below the key highlights of the Regulation relating to the utilization of e-SIM.
- Key Obligations for Telecommunication Providers in relation to e-SIM UtilizationThe implementation of the e-SIM technology may only be carried out by telecommunications providers classified as Mobile Cellular Network Operators and Satellite Mobile Network Operators (collectively, the “Providers”). The Providers are required to fulfill several key obligations as follows:
- System Provisioning: Providers must establish and operate systems that support the use of local International Mobile Subscriber Identity Numbers (the “IMSI Numbers”) and manage subscriptions involving local Mobile Subscriber Integrated Services Digital Network Numbers and the IMSI Numbers. In relation to the provision and operation of system provisioning, the Providers may cooperate with third parties that meet the requirements set forth in the Regulation.
- Customer Registration: The Providers are required to carry out customer registration in accordance with applicable laws and regulations.
- e-SIM Profile Storage and Protection: e-SIM profiles must be secure and protected within the provisioning system. The Providers must implement and comply with standard operating procedures aligned with data protection and privacy regulations.
- Data Security Certification: The Providers must meet the certification requirements under the approved data security accreditation scheme for their provision systems.
- Monitoring and Evaluation of e-SIM Utilization
The Government has enacted regulatory measures to monitor and evaluate such utilization of the implementation of e-SIM. This oversight shall be conducted based on report by the Providers, public complaints and/or on-site inspections. Failure by the Providers to fulfill obligations under this Regulation may result in administrative sanctions, including a written warning and/or public disclosure of the violation. - Transitional Provisions Upon Enactment of Regulation
The Providers and any other parties that implemented e-SIM utilization prior to the Regulation are granted a two-year transitional period to achieve full compliance with its provisions.
AKSET
Please contact Johannes C. Sahetapy-Engel (jsahetapyengel@aksetlaw.com) or Unisya Izhari Rinsta Savira (usavira@aksetlaw.com) for further information.
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