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Singapore launches public consultation on embedded SIM technology to facilitate IoT deployment

At the
recent 5G Workshop on the 5G Commercialisation and Deployment Roadmap, Infocomm
Media Development Authority (IMDA) announced
the launch of a public consultation on embedded SIM technology to facilitate
innovation, competition and IoT deployment.

Through this public consultation, IMDA would like to seek views
and comments from members of the public and the industry on IMDA’s preliminary
views and assessment of the impact of eSIM technology in Singapore’s context.

According to the Consultation
, the next round of technology innovation in Subscriber
Identity Module (SIM) cards involves an evolution of the card form factor,
where the circuitry of the physical SIM card is now physically and permanently
integrated into different devices, i.e., it can no longer be removed from the
device. Th embedded SIM cards or eSIMs are typically soldered directly into the
devices during the manufacturing process by equipment manufacturers.

Alongside the introduction of eSIMs, it is possible to
remotely change a mobile operator’s profile in a SIM card without having to
physically change the SIM itself. This function is called remote provisioning.
While remote provisioning is a new function, the eSIM technology is also
backwards compatible, which means that it can be implemented on any SIM form
factor, including physical SIM cards and eSIMs.

The combination of eSIM and Remote Provisioning
functionality will enable over-the-air (“OTA”) management of mobile operator
profiles for more efficient service provisioning and switching between mobile
operators. For example, end users will be able to switch between mobile
operators without physically swapping their SIM cards, reducing visits to brick
and mortar stores.

The development of eSIM technology will bring about
benefits, in enabling greater choice of mobile operators and more competitive
service plans, for both consumer devices including smart phones, tablets and
wearables such as smart watches, as well as Machine-to-Machine (M2M)
communication devices and/or Internet of Things devices (IoT) typically
deployed by enterprise users.

As such, the consultation seeks to discuss four major issues
of eSIM:

SIM-Lock Policy

Introduced in 1997, the No SIM-lock policy states that
mobile operators are not allowed to SIM-lock devices to SIM-lock devices that
are imported and sold in Singapore. This policy aimed to remove the barrier for
end users to switch mobile operators, so as to facilitate competition and
provide end users the freedom to choose and switch between mobile operators
without the need to change their consumer devices.

Although the deployment of eSIMs is at a nascent phase in
Singapore, IMDA would like to ensure that the deployment of eSIM technology is
consistent with the existing No SIM-Lock policy. As a starting premise, the No
SIM-lock policy should continue to apply to mobile operators for eSIM-enabled
consumer devices, such as mobile phones, tablets and wearables, whether they
are purchased by consumers or enterprise end users.

At the same time, IMDA is cognisant that eSIMs are increasingly
being used in M2M devices to facilitate automated communication between
machines and devices, and often times within a closed, pre-defined network. The
connectivity services are likely to be bundled and sold as a package with the
devices or are procured separately but intended primarily for enterprise use.
It was said that IMDA is prepared to allow the industry some flexibility in
applying the No SIM-lock policy, as some of these enterprise users may choose
to stay with a single mobile operator based on the terms negotiated for the
provision of M2M services.


The Global
System for Mobile Communications Association
(GSMA), the global body
of mobile operators and related vendors worldwide, has released two different
technical specifications for two categories of eSIMs devices: consumer devices
and M2M devices.

IMDA expects eSIM devices that are brought into Singapore
for sale and use in Singapore to conform to these GSMA specifications moving
forward. The adoption of GSMA specifications will enable the remote
provisioning of mobile operators’ profiles regardless of the SIM manufacturers
and solution providers, achieving the No SIM-Lock policy intent and facilitating
technical switching across mobile operators’ networks,

Business and Operating Models

Today, there are several business models in the provisioning
of eSIM-enabled services. They include fully outsourced model where the various
functional blocks are fully managed by third parties, fully in-house model
where the various functional blocks are fully managed by mobile operators, and
hybrid model which a mobile operator’s profile packaging and management are
managed by one party while services such as profile switching and service
activation are managed by another party.

IMDA seeks views on the possible business and operating models for eSIM-related service provisioning, including the pros and cons of each approach, as well as the opportunities for Singapore in developing an eSIM ecosystem.

and Regulation and eSIM Devices and Services

Currently, all manufacturers, importers and sellers of
SIM-enabled devices, and mobile operators who provide the connectivity for
SIM-enabled devices, are required to apply for a Telecommunication Dealer’s
licence and telecommunication service provider’s licence respectively from

Depending on the device capabilities and characteristics of
the services provided, IMDA requires the manufacturer, importer and seller of consumer
devices, and the connectivity service provider for Consumer devices, to
minimally obtain a Telecommunication Dealer’s (Class) licence and a
telecommunication operator licence respectively.

For M2M devices, the manufacturer, importer and seller is required
to obtain a Telecommunication
Dealer’s (Individual) licence
, and the connectivity service provider
is required to obtain a telecommunication
operator licence for the provision of M2M services

The licensing and regulatory framework is aimed at ensuring
that the devices imported for use in Singapore comply with the relevant
standards and technical requirements in the use of radio frequencies, to ensure
public safety and security needs are met, and that consumer interests are

In the public consultation, IMDA proposes to maintain the
current licensing framework only for M2M devices that support mobility and/or
come with restricted voice communication features for public safety reasons.
This will cover M2M devices with or without restricted voice communication
features that are used in motor vehicles and trains, and M2M devices that come
with restricted voice communication features.

For all other M2M devices, IMDA proposes to adopt a
“light-touch” licensing approach where the device manufacturer, importer and
seller is only required to register the M2M device and obtain a
Telecommunication Dealer’s (Class) licence, without additional record keeping
licence obligations.

The consultation is part of IMDA’s on-going efforts to
facilitate market innovation and competition as eSIM-related technologies
evolve and adoption grows. As
Singapore journeys towards a digital economy, IMDA hopes to continue working
with mobile network operators, technology providers and other government
organisations to create a sustainable communications ecosystem for the benefit
of industry and society. The public consultation is open for submissions till
12 noon, 18 July 2018.

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