Update on Sim registration to Parliament of Ghana

“Previous SIM Registration exercises which had purportedly been undertaken were plagued with multiple challenges which defeated the purpose of the exercise”

1. Introduction and Rationale for the SIM Registration

I thank the House for granting me this opportunity to present an update on the National SIM Registration Exercise we begun some 20 months on 1st October, 2021 which has finally come to a close with resounding success.

As you may recall, previous SIM Registration exercises which had purportedly been undertaken were plagued with multiple challenges which defeated the purpose of the exercise. These included:

• The use of multiple IDs including the Driving License, Voter’s ID, National Health Insurance cards and Passport, with no means of verifying their authenticity. Indeed, an attempt made by the NCAto verify Passports by a manual, laborious and unsustainable process was eventually abandoned as impractical. This lack of verification allowed the agents of Mobile Network Operators (MNOs) to use fake IDs and valid IDs of unsuspecting individuals to pre-register SIMs for sale.
• The databases created were unreliable leading to the inability of Security and Law Enforcement Agencies to trace IDs of individuals involved in SIM-related breaches of the law
• There was no limit on the number of SIM Cards registered by an individual, resulting in fraudsters registering multiple SIMs to perpetrate scams and defraud innocent citizens. Sim box fraud was also rampant, depriving both the MNOs and the Government ofmuch needed revenue.
• The lack of a Central SIM Registration Database disabled the regulator, NCA, from independently and adequately monitoring registrations that had been completed as well as the activities of the MNOs regarding SIM registration. Indeed, we only had the word of the MNOs regarding the number of SIMs in use in Ghana and lacked independent empirical data to enable us take key decisions related to the development of the communications industry.
• There was no way of ensuring compliance with the National Identity Register Regulations, 2012, LI 2111 which mandated all SIMs to be registered with the Ghana

These were the reasons why it was important to undertake a clean SIM Registration Exercise which would address these challenges and be in conformity with existing laws and regulations.

• https://mypublisher24.com/the-rod-that-was-handed-ndc-for-adamu-sakendes-back-is-ready-for-gyakye-quayson/

Ghana is rapidly developing a digital economy and we must take steps to ensure that we build resilient systems that inspire trust in the use of digital platforms, applications and services. The digital ecosystem must be secure enough to protect citizens, users of communications services and Government investments as well as private investments in the sector. A porous SIM acquisition and utilisation system as we had, prone to fraud and abuse, only served to diminish public confidence in the digital ecosystem with each successful undetected and unpunished SIM-based fraudulent or criminal activity.

2. Stakeholder Engagement

To ensure the successful implementation of the SIM Registration Exercise, the Ministry of Communications and Digitalisation convened several meetings with all stakeholders and mandated the National Communications Authority (NCA) to collaborate with all Mobile Network Operators (MNOs) as they play a key role in the provision of telecommunication services and have direct interaction with subscribers and Broadband Wireless Access (BWA) Providers to ensure that the registration exercise covered the entire range of SIM card issuing providers of telecommunication services, including broadband Internet.

Several key government Ministries, Departments and Agencies were also involved to provide support and contribute their expertise to the registration process. These included:

• Ministry of Foreign Affairs & Regional Integration (MFARI)
• Ministry of Information (MoI)
• NationalInformation Technology Agency (NITA)
• TheRegistrar of Companies, formerly the Registrar General’s Department (RGD)
• GhanaImmigration Service (GIS)
• DataProtection Commission (DPC)
• NationalIdentification Authority (NIA)

3. Legal Framework

The team considered and applied the following pieces of legislation in this exercise:

Electronic Communications Act, 2008 (Act 775), Subscriber Identity Module Registration Regulations, 2011 (LI 2006), Data Protection Act, 2012 (Act 843), National Identity Register

Regulations, 2012, LI 2111 and Executive Instrument 63, 2020.

4. Modalities of the Registration

The registration of SIM cards was conducted using the Ghana Card as the sole identity document in line with the provisions of the National Identity Register Regulations, 2012, LI 2111, and the Subscriber Identity Module Registration Regulations, 2011, LI 2006. This ensures that subscribers’ identification is linked to their national identification card.

As a first step, all subscribers were required to link their SIMS to their Ghana Card to verify their details with the National Identification Authority (NIA) database.

Once this process is completed, the biometric data of the subscriber is collected. This includes fingerprint and facial data, obtained through a positive Likeness and Liveliness check. This was to provide a kind of double-factor authentication and ensure that the Ghana card of one person could not be used by another person to register their card. Biometric data enhanced the accuracy and security of SIM registration.

The exercise imposed limits on the number of SIM cards an individual can possess. Each citizen and resident foreigner with a Ghana card is allowed a maximum of 10 SIMs, while foreign visitors are limited to 3 SIMs across all networks.

A Central SIM Register has been established to serve as a central repository of SIM card information and enhance regulatory oversight and security.

To facilitate the process and provide guidance, two committees, namely the Technical and Communications Committees, were established and an Operational Support Centre (OSC) was also set up at the NCA to assist consumers and the general public with any issues related to the registration process.

5. Extensions of the Exercise

Within the 20-month period of the SIM Registration, we have extended deadlines seven (7) times in a bid to encourage people to register their SIMs. The notable dates of the SIM Registration Exercise are as follows.

Table 1: SIM Registration Deadlines

This has not been an easy journey.

8. Protecting the Integrity of the SIM Register

To safeguard the integrity of the SIM register, the NCA issued specific directives to MNOs, including:

Completion of classification or categorization of all SIM ownership into individual or business SIMs.

Deactivation of all SIMs that are partially registered (stage one). Strict application of the limit of 10 SIMs for individual subscribers.

Development of a solution to enable subscribers to check the number of SIMs registered with their Ghana Cards using a short code 402.

Implementation of a process for consumers to delink SIM cards from their Ghana Cards through customer care centres, ensuring proper KYC verification.

Development of enterprise and web-based systems for businesses to check and delink unused or unwanted SIMs.

9. Subscribers Exempted from the SIM Registration

In addition to the established guidelines and deadlines for the SIM Registration Exercise, certain categories of subscribers have been exempted from punitive measures for non-registration. These include exemptions for individuals without Ghana Cards who notify the NCA with proof of application for the Ghana card, subscribers outside the country and subscribers facing genuine challenges during the registration process.

Table 2 provides the list of categories and the number of exemptions given per category.

Table 2: List of Exemptions

In Recognition of the fact that not everyone has a Ghana Card, individuals who have not registered have been asked to submit evidence of having applied for their Ghana Card to the NCA.

Subscribers who are currently outside the country have also been exempted from the registration process. Once they activate roaming on their phones, the MNOs can identify that they are outside the country and they are expected to register their SIM cards using their passports. The NCA has directed that SIM cards detected to be outside the country for a period of 6 months should be temporarily exempted until the subscribers can complete their registration.

Some subscribers may also encounter genuine difficulties in completing their registration and the NCA has directed them to contact the NCA for assistance via email or the SIM Operational Support Centre (Toll-Free 0800-110-622). The complaint will be investigated and they may temporarily exclude the affected SIM cards from punitive measures until their concerns are resolved. This will however be done on a case by case basis, recognising that not all people may want to register their sims as is their right.

10. Challenges/Issues Arising from the Current SIM Registration Exercise

One issue that emerged was the registration of more than 10 SIMs per individual subscriber. Only Corporate entities are allowed to register more than 10 SIMs however, some subscribers registered more than the permitted number due to the incomplete classification field for SIM registrations shared with the Central SIM Register. Mobile Network Operators (MNOs) requested time to reconfigure their databases to properly classify SIM registrations, leading to this loophole. This has since been resolved with subscribers able to check how many SIMs are linked to their Ghana Cards through a dedicated USSD code. The Central database has also been updated accordingly.

During the initial stage of the SIM Registration Exercise, some MNOs continued to use their old legacy platforms for registration. This led to abuse by certain agents in the registration process during stage one and the NCA directed MNOs to discontinue using the legacy platform and complete the full SIM registration process, including biometric capture. The NCA also out doored the short code 402 to let people check and rectify any discrepancies. It is important to note that the legacy platform only allowed completion of stage one which does not require biometric data and therefore cannot complete the process.

There were claims of database breaches during the exercise. Upon investigations, no unauthorized access or breach of the SIM registration database was discovered. The identified abuses during stage one were resolved and did not involve unauthorized access to the SIM registration database. No one’s identity or personal information has been stolen or compromised in this process.

From 1st June, 2023, to date, the NCA has been monitoring the situation and it is interesting to note that at the MNOs Customer Care Centres, there are people with Ghana Cards who had simply not registered their SIMs. This demonstrates that even if there had been another extension of the deadline, we would still have had people who would simply not have registered their SIMs. They probably assumed that as is characteristic of Ghanaians, a little public outcry would have led to a knee-jerk reaction of truncating this exercise but with the enforcement of the deadline, these people have now lined up to register their SIMs knowing we are serious about this.

Some people who had used their lack of a Ghana Card as an excuse not to register are now finding means of acquiring the Ghana Card or have reached out to the NCA as they had always been directed to do, to ring fence their SIMs while they await their Ghana Card. We will not encourage any anonymity in this exercise and reiterate that those who have genuine challenges acquiring the Ghana card to complete their SIM registration should contact the NCA with evidence of applying for the card and their challenge will be addressed after investigating it. We continue to encourage the NIA to assist people to acquire their Ghana Cards.

We have also been made aware of the difficulty facing subscribers in accessing their funds on their mobile money wallets. These subscribers will not be able to transact any mobile money related activity, however, MNOs are working with the Bank of Ghana to ensure that these subscribers can retrieve their funds on the presentation of a valid ID and completion of the relevant KYC process. To transact mobile money related activity, the subscriber will have to complete their registration for the MNO to reactivate the SIM on the network.

This is an area where multiple regulatory mandates converge and it is absolutely critical for the regulator of financial services in Ghana, the Bank of Ghana, to collaborate closely with the regulator of the technological and telecommunications platforms to deliver those digital financial services, the National Communications Authority. I said so during the passage of the Payment Systems and Services Act, 2019, Act 987, in this very house and in other fora and was ignored. I hope we have now learnt our lessons and will desist from unnecessary turf wars and learn to work together in the interest of the ordinary citizen.

Another concern received is the claim that some agents are charging subscribers to register their SIMs. MNOs have been directed to inform their agents to desist from this practice failing which any agent caught in such an act will be punished. I’ll urge any victim of this illegal act to notify the NCA promptly and action will be taken to deter this practice.

I have also heard some people complain that through they had registered their SIMs they were blocked. My information is that several of these complaints are from people who did not complete the registration process – that is though they linked their Ghana Cards with their SIMs, they did not do the biocapture as required. Such people should contact their MNOs to have the issues resolved and owners of the SIMs will get their numbers back after duly registering. They must however act timeously as the NCA will shortly announce when this moratorium will end after which all unregistered numbers will be permanently blocked from the networks. If your line has been blocked and you still need it, go and register.

There may however be some whose SIMs are blocked inadvertently even after full registration. Kindly notify the NCA, and a full investigation will be conducted to determine if this was really the case and why it happened. The MNOs are to ensure that their systems work and no one who has fully registered their SIMs should have it blocked.

11. What Have We Achieved So Far and the Impacts of the SIM Registration

Right now every registered SIM is linked to a Ghana Card that has had the ownership of the Ghana Card verified from the NIA. Visiting Foreigners have registered their SIM with their passports and they are only active for 90 days. Almost 30 million SIMs have been registered and can be accounted for after 20 months of this registration exercise and that is no mean feat.

Limits have been set on Individual SIM Ownership; Ghanaians and Resident Foreigners have a limit of 10, Visiting Foreigners have a limit of 3 and corporate entities do not have a limit, however, their SIMs are tied to the Ghana Card of a Director of the entity.

Today, Ghana, through the Ministry of Communications and Digitalisation, can boast of an independent National SIM Register which mirrors the SIM Registers of the various MNOs. For the very first time in our history, we can accurately project the impact of decisions and actions taken by stakeholders without hazarding guesses. This database is also in the process of being linked to other institutional databases like the GRA to create a data lake and have a more accurate picture of mobile usage and spending patterns.

Individual SIM owners can check the number of SIMs linked to their Ghana Cards to address the issue of SIMs fraudulently registered with other people’s IDs. NCA will be working with the MNOs to ensure that a similar platform is created for corporate entities to be able to do the same shortly.

Through the SIM Registration exercise, we have ensured that commercial operations which were hitherto being conducted without the relevant business registration documents are streamlining their registration processes with the Registrar of Companies. You need proper corporate registration documents to register your corporate SIMs.

While the Ghana Card is mandatory for accessing various Government Services, we can confidently state that no single service has had the majority of Ghanaian users apart from Communications services. Undoubtedly, the SIM Registration exercise has galvanised more Ghanaians to register for their Ghana Cards than any other exercise so far, ensuring that we have a more comprehensive national ID database.

Through the operations of the SIM Registration Forensic Audit Team, the MNOs will be compelled to keep a sanitised SIM Register making it easier for the Security Agencies to track suspected criminals or fraudsters on the presentation of a court order. As the IGP indicated recently, the incidence of SIM based fraud has reduced markedly since the registration exercise started. SIMboxing has almost completely disappeared. It will decline even further with the blocking of unregistered SIMs used to commit or facilitate criminal activity.

In terms of National Security, the SIM registration will contribute significantly to enhancing national security by reducing the anonymity of mobile phone users. The availability of accurate subscriber information aids law enforcement agencies in investigating and preventing criminal activities.

SIM registration will facilitate the implementation of various government initiatives, such as mobile money services, digital financial services and other electronic transactions. Accurate subscriber identification enables the expansion of these services and enhances financial inclusion.

By registering SIM cards, citizens are better protected against fraud, unsolicited messages, and other forms of misuse of mobile phone services. The ability to identify and track individuals engaging in illegal activities provides a sense of security to mobile phone users.

The statistics of Current Active SIMs

Table 3: Active SIMs Statistics as of 6th June 2023

• Numberof Unique Ghana Card Registrations: 14,189,218

Table 4: SIM Registration Data at the Inception of SIM Registration Exercise as well as blocked and delinked SIMs.

12. Reactivation of Blocked SIMs since 31st May, 2023

Since the final deadline, increased activity indicates that some of these blocked SIMs are being reactivated following the completion of all necessary processes; however, it is important to note that not all the blocked SIMs are expected on the network as some of these SIMs were pre- registered SIMs being used for fraud, some were also for subscribers who may not want to use these SIMs again. I am also informed that almost 280,000 merchant SIMs have not been registered and a viral video doing the rounds of social media a few weeks ago indicated that some criminal networks have acquired merchant SIMs to facilitate their fraudulent activities. Let me reiterate once again that all unregistered merchant SIMs will be blocked permanently at the end of June 2023.

The table below shows the number of reactivated SIMs since 1st June, 2023:

Table 5: Reactivated SIMs from 1st to 6th June, 2023

*Vodafone in their report to NCA indicated that some subscribers registered for new SIMs instead of reactivating their existing SIMs. The total number of such registrations is 58,737, so only 18,673 SIMs have been reactivated. This occurrence is mainly due to these subscribers previously having preregistered SIMs.

13. Going Forward – Forensic Audit of SIM Database

As mentioned earlier, the NCA has established a SIM Registration Forensic Audit Team tasked to Validate the integrity of the service provider’s data in the Central SIM Register database; Identify discrepancies or inconsistencies between the service providers’ database and the Central SIM Register database; Evaluate the effectiveness of data synchronization processes; Assess the accuracy and completeness of the Central SIM Register database; Review data entry processes and security controls to mitigate the risk of data manipulation or corruption and Confirm the accuracy of SIM registration data in accordance with the requirement of the SIM Regulations and directives of the Authority.

14. Conclusion

My information is that the SIM cards of some Members of Parliament and even the Speaker and leadership were affected by this exercise. The MNOs have been to Parliament several times to assist members to complete the process and will continue to work with the Clerks office to facilitate registration for those who want to complete the exercise.

By implementing a comprehensive SIM registration process, the government aims to reduce fraud, enhance security, and promote responsible use of SIM cards for the benefit of all.

I am counting on the support of colleague MPs to complete this project which will inure to the benefit of all the good people of Ghana.

I thank Ghanaians, all SIM users and all the stakeholders involved in this process for their cooperation as we seek to build a Digital Ghana based on sound, secure foundational digital infrastructure including a robust National SIM Registry.

Mr. Speaker, It is DIGITIME in Ghana!!