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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 Paper, 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:

(1)    No 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.

(2)    eSIM Technology

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,

(3)    eSIM 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.

(4)    Licensing 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 IMDA.

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 protected

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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