The Implications of Mandatory SIM Registration for Refugees, Stateless and Forcibly Displaced Persons
Mobile phones are increasingly necessary to communicate and to access many critical digital services, including mobile money accounts. At the same time, however, stringent regulations around mobile registration -- and specifically registration of SIM cards necessary to identify and authenticate users -- make it difficult for many people to access these services.
At a roundtable event hosted by the GSMA in New York and at a workshop co-hosted by ID2020 and UNHCR in Munich in November, stakeholders discussed digital identity opportunities for refugees, stateless and forcibly displaced persons. In both instances, attendees acknowledged and reflected upon the important role of mobile services in opening up opportunities for these people as well as the positive externalities for host-communities and humanitarian agencies. However, current ‘Know Your Customer’ (KYC) requirements for SIM registration effectively deny many of these people access to mobile services.
Currently, at least 135 countries -- including the top 10 refugee hosting countries by volume -- mandate mobile SIM registration, require consumers to provide valid proof-of-identity in order to activate and use a mobile SIM card. This requirement excludes many vulnerable consumers who lack the documentation necessary to fulfill KYC criteria from registering a SIM card. As such, this often is a key barrier to financial inclusion.
The requirements for SIM card registration and accepted forms of identification vary by country, but limitations often make registration difficult if not impossible for forcibly displaced persons who disproportionately lack even the most basic form of identification upon arriving in a new country.
In Bangladesh, for example, the government has recently banned mobile phone operators from selling SIM cards to Rohingya refugees fleeing the violence in Myanmar, citing security concerns. The policy indicates that the form of identification held by the Rohingya is insufficient to meet valid identification requirements. The government is conducting a 6-month biometric registration process of the refugees, after which the ban could potentially be lifted.
In the meantime, however, the current policy does not make the allowances necessary for refugees to use mobile SIM cards legally. In this vacuum, the demand for black-market SIMs has led to local traders reportedly reusing the fingerprints of unaware and illiterate locals to sell biometrics-backed SIMs to the Rohingyas at a much higher price. The Bangladeshi government has already sentenced 20 people for illegally selling SIM cards.
Like refugees everywhere, the Rohingya rely on mobile services for communication with friends and families as well as other mobile services. The Rohingya have access to state-run Teletalk phone booths in the refugee camps for free contact with friends and family, but these booths are not conducive for frequent use nor do they allow access to mobile services or accounts.
GSMA’s recent report, Enabling Access to Mobile Services for the Forcibly Displaced, outlines a set of policy and regulatory considerations for addressing identity-related barriers preventing forcibly displaced persons from accessing mobile services. GSMA’s considerations, intended for host-country governments and regulators (including central banks), seek to make SIM card registration easier by promoting the adoption of flexible and proportionate approaches towards proof-of-identity requirements for forcibly displaced persons to access mobile services. The considerations urge policymakers to ensure that citizens, residents and refugees in their country are able to access the types of identity credentials that are listed as acceptable proof of identity for the purposes of signing up for mobile services.
While a number of countries currently recognize UNHCR-issued identification as acceptable proof-of-identity for SIM registration or KYC requirements (including Jordan, Iraq, Afghanistan, Egypt, Rwanda, Pakistan, the Philippines and Haiti), GSMA advocates for broader recognition of the UNHCR-issued identification in order to enable refugees upon arrival to access mobile SIMs, wallets, SIM-based energy products, and more.
This conversation around SIM registration is emblematic of a larger conversation: how do we ensure that refugees and other forcibly displaced populations are able to portably, persistently and privately prove who they are? While broader recognition of existing documents is certainly of benefit, participants in both the GSMA roundtable and the Munich workshop expressed a belief that digital identity — particularly if individuals are given agency over their own identity and associated data — could allow individuals to persistently prove who they are to diverse organizations and in many different scenarios.
This is what the ID2020 Alliance is all about. As a multi-sectoral partnership, the Alliance brings stakeholders together to coordinate on technical and non-technical topics alike. The technical standards set by Alliance partners can facilitate interoperability, ensure trustworthiness and drive broad recognition. On the non-technical side, Alliance will provide sustainable financing for interoperable identity systems to ensure that current siloed, non-interoperable approaches do not continue. This coordination is crucial for digital identity to meet the needs of governments, international organizations, businesses and individuals alike.