Mandatory SIM Card Registration as a Socio-technical Assemblage: Bio-identity, Everyday Surveillance and the Limits of the Evidence
Emmanuel de Atocha Zamora-Hoil
Abstract
Mandatory registration of SIM cards is now the norm rather than the
exception: more than 160 governments require it and just over 35 also demand
biometric data. From a Science, Technology and Society (STS) viewpoint this
study looks at the measure as a socio-technical ensemble of legal identity,
biometric traits, mobile access and state-operator data infrastructure. The
sampling frame for selecting the nine cases used in the study is based on
Comparitech's 2025 country data set. A diverse case design was employed to
choose nine cases which met the inclusion criteria and could be traced back to
their primary legal, regulatory or judicial source(s) when possible. These
include: Tanzania, Kenya, Uganda, Mauritius, Pakistan, Romania, Mexico, the
Philippines and those countries that do not require registration. To compare
with the document analysis portion of the study, peer-reviewed literature was
used to examine the adoption, consequences and user experiences of the
registration schemes. Across all cases there is a pattern of mass disconnection;
irregular registration being circumvented; constitutional invalidations;
revocations and repeating policies. In addition, there are reports from
governments about successful implementation of registration schemes which
have not undergone independent evaluations. Therefore, while it is clear that
registration schemes do not provide evidence of effectiveness, they do
demonstrate significant costs related to privacy and inclusiveness. Based upon
these findings, the author recommends that prior to introducing new or
renewing existing registration schemes (such as Mexico's 2025-2026
identification scheme), there must be a proportionality assessment conducted;
independent evaluations performed; and data minimization implemented.