data privacy

[ANALYSIS] Unintended consequences of the SIM Registration Act

JC Punongbayan

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[ANALYSIS] Unintended consequences of the SIM Registration Act
Don’t be surprised if a network of SIM syndicates arises on our shores sooner rather than later

On October 10, 2022, President Ferdinand Marcos Jr. signed into law the SIM Registration Act (the first law he signed).

Basically, it requires people to register their SIM (Subscriber Identity Module) cards before April 26, 2023. Otherwise, those SIM cards will be deactivated permanently. New SIMs are also deactivated by default, and can only be activated by registration.

The deadline was originally April 26, 2023. But a day before that, April 25, the Marcos government extended it by 90 more days to July 25.

The law is well-meaning. According to its declaration of policy, it aims to “promote responsibility in the use of [SIM] and provide law enforcement agencies the tools to resolve crimes which involve its utilization and a platform to deter the commission of wrongdoings.”

Lawmakers also said this will help combat the proliferation of those pesky text scams that keep flooding our phones. Meanwhile, in its blaring emergency alerts that disrupted our lives on April 23 and 24, Globe implored people to register to “make the online space safe for everyone.”

However, there are early signs that the SIM registration law will not meet all its objectives. It even created new problems.

Black market

For instance, the law already inadvertently created a budding black market for registered SIM cards.

On April 4, authorities arrested a Chinese businessman and a Filipino who were allegedly selling pre-registered SIM cards to Chinese and Filipinos for P1,500 to P2,500 apiece. Authorities confiscated 100 such SIM cards, which were named under fictitious names and reportedly linked to a mobile wallet app.

This is the first arrest under the SIM Registration Act. Charges were also filed against the two for violating the Cybercrime Prevention Act of 2012.

If the buying and selling of registered SIMs can happen before April 26, it can happen after that as well.

So despite the law, there’s nothing really stopping scammers from still inundating our phones with those messages. Other bad actors can still use SIMs for whatever crime or misdeed.

We should’ve learned from lessons abroad.

In June 2022, Malaysian authorities arrested seven people involved in a SIM registration syndicate. Police said those arrested were “found using personal data of locals and foreigners given by other syndicates to illegally activate the prepaid SIM cards.”

Don’t be surprised if a network of SIM syndicates arises on our shores sooner rather than later.


There are other complications of the law.

First is the very slow pace of registration. As of April 23, only 82.8 million SIMs have been registered. That’s just 49% of all SIMs out there.

The remaining 51% represents a huge potential loss in various aspects of telcos’ businesses. Before the original April 26 deadline, telecom companies worried a lot that they will have to deactivate millions of SIMs.

The stakes are so huge that Globe piggybacked on the country’s emergency cell broadcast system to remind subscribers – even those who have registered already – to register. This got the nod of the National Disaster Risk Reduction and Management Council.

Said Globe in a later statement, “The lack of mobile services is in itself an emergency, severely impacting daily life, from financial transactions and e-commerce to transport and education, among many others.”

True enough. Failure to register millions of SIMs spells mass disenfranchisement of Filipinos, not just in terms of telecom services but also financial services (think GCash), transportation services, and even healthcare services. This is in light of the ever-expanding usage of mobile phones and apps in our day-to-day lives. 

Think of poor Filipinos who still use prepaid mobile phones with keypads with no Wi-Fi or data access. How can they be expected to register their SIMs on time?

Some vendors of SIM cards are already helping out SIM registrants, but for a fee of P20-P50. This is yet another market inadvertently created by the SIM Registration Act, which stipulated that SIM registration should be free.

Whole sectors might be left out. Said the leader of the Kilusang Magbubukid ng Pilipinas, “The threat of [farmers, fisherfolk, and people in the countryside] losing their access to their SIM and other social media is a direct attack [on] their right to be heard, be informed and communicate.”

Also, think of people who have difficulty producing the documents required, especially government IDs. To go around this, some are registering using other people’s names, based on a report.

Those with smartphones and using e-wallets may also face problems. If they don’t register on time, can they still get their money in their e-wallets, or will it vanish in thin air?

By the way, for foreigners touring the country and wishing to use SIM cards, the law’s requirements are onerous, too. They need to register their SIMs using their full name, nationality, and passport number, and even present their proof of address in the Philippines as well as their return ticket! I wish I were joking.

For foreigners with other visas, they need to present their alien employment permit (AEP), alien certificate of registration ID, school registration/ID (if applicable), and “other pertinent documents.”

If you go to other countries, getting a SIM for traveling is as easy as buying one from the airport and popping it into your phone. That’s it. Why do we need to make it so difficult in the Philippines now? Might this harm tourism?

Ideally, such complications should’ve been incorporated by the lawmakers. But they seem to have brushed aside those concerns, which are now posing a real threat to people’s everyday lives.

Privacy concerns

Then, of course, there are privacy concerns.

When you register your SIM, you need to put in your mobile phone number, full name, birthday, complete address, sex, a government-issued ID, and a selfie photo.

That’s a lot of info to harvest from tens of millions of consumers, who might be increasingly wary of sharing their information because of the string of data leaks of late.

Recently, more than 1.2 million records were leaked from government agencies like the Philippine National Police, National Bureau of Investigation, Bureau of Internal Revenue, and the Civil Service Commission.

These data include “passports, birth and marriage certificates, drivers’ licenses, academic transcripts, security clearance documents,” and even tax identification numbers and employment recommendation letters.

Although there are safeguards in the SIM Registration Law enjoining telco companies to maintain secure databases of SIM registrants, the government can still easily gain access to such data by means of a mere subpoena issued by a “competent authority.” Might this be abused?

If the government can’t protect our data before, how can the SIM Registration Act protect our data moving forward?

Just extend the deadline?

One obvious solution to the looming telecommunications crisis is to just extend the deadline for SIM registration. The Marcos government did exactly that, with their 90-day extension.

On the one hand, this makes perfect sense. In other countries, SIM registration lasts for one or two years – not six months after the law was passed. Just give people more time.

On the other hand, postponing the deadline is not costless either. More than anything else, it erodes the credibility of the government, which can’t commit to its own deadlines. What’s to prevent yet another extension come July 25?

Secretary Ivan John Uy of the Department of Information and Communications Technology (DICT) also hinted that for those not yet registered by April 26, some services might be discontinued (e.g., social media). This is meant to give people a foretaste of what will happen if they still don’t register their SIMs. He said some people are just “hard-headed.”

But what are those services that will be discontinued? How will they be chosen? For how long will they be discontinued? And is this enough to encourage registration if many of those not yet registered are precisely those with keypad phones and no Wi-Fi or data access – and don’t really use social media to begin with?

I wouldn’t be surprised if thousands of Filipinos will still be disenfranchised after July 25.

In the end, the SIM Registration Act is yet another one of those legalized bans. This time, it’s a ban on unregistered SIMs. But history and economics show us that legalized bans are often ineffective. People are creative and will do everything to go around any ban. Haven’t we learned from Duterte’s inutile war on drugs? –

JC Punongbayan, PhD is an assistant professor at the UP School of Economics and the author of False Nostalgia: The Marcos “Golden Age” Myths and How to Debunk Them. JC’s views are independent of his affiliations. Follow him on Twitter (@jcpunongbayan) and Usapang Econ Podcast.

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JC Punongbayan

Jan Carlo “JC” Punongbayan, PhD is an assistant professor at the University of the Philippines School of Economics (UPSE). His professional experience includes the Securities and Exchange Commission, the World Bank Office in Manila, the Far Eastern University Public Policy Center, and the National Economic and Development Authority. JC writes a weekly economics column for He is also co-founder of and co-host of Usapang Econ Podcast.