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In brief

On 10 October 2022, President Ferdinand Marcos Jr. signed into law Republic Act No. 11934, otherwise known as the “Subscriber Identity Module (SIM) Registration Act”.  The primary purpose of the Act is to mandate all public telecommunications entities (PTEs) to require the registration of SIM cards prior to their sale and activation, in an effort to promote accountability and provide law enforcement with an identification tool in resolving crimes.

Under the Act, the National Telecommunications Commission (NTC), in coordination with concerned agencies such as the Department of Information and Communications Technology (DICT), the Department of Trade and Industry (DTI), the National Privacy Commission (NPC), as well as PTEs and major consumer groups, is mandated to issue the implementing rules and regulations (IRR) necessary for the implementation of the SIM Registration Act.

The NTC issued the IRR via Memorandum Circular No. 001-12-2022 on 12 December 2022. The IRR is reported to take effect on 27 December 2022, 15 days after its publication in the Official Gazette or in a newspaper of general circulation.

Registration, in more detail

The SIM Registration Act IRR reiterated the end-users’ mandatory registration of SIMs with their respective PTEs for the activation and use thereof. Failure to register the SIM with the respective PTEs will result in the SIM not being activated for use.

PTEs and their agents, resellers, and other entities must sell SIMs in a deactivated state and activate the SIMs only after the end-users complete the registration process. Existing SIMs in use will automatically be deactivated if the existing subscribers/end-users fail to register with the PTE within the prescribed period.

The IRR details that the PTE registration process include the submission of information (e.g., name, date of birth, sex, present or official address, type of ID and ID number for individual end-users, and business name, address, and authorized signatory for juridical entity end-users), presentation of valid government-issued ID or similar form of document with photo, and input of the assigned mobile number of the SIM with its serial number.

PTEs must verify the submitted information, maintain a database with these information, and process the same only for the purposes of SIM activation/deactivation. 

Foreign SIM end-users may only use their registered SIMs for 30 days, but may avail of longer period by submitting an approved extended visa to their respective PTEs. Foreign SIM end-users may register their SIMs using their passport and/or visa.

Other notable provisions

Aside from registration, end-users are also required to immediately notify their respective PTEs of any change of information supplied, report a lost or stolen SIM, and the death of an immediate family member end-user. Selling or transferring SIMs is prohibited, without complying with registration requirements under the IRR.

PTEs are required to establish a SIM registration platform, maintain a database for these information, and deactivate SIM upon report of stolen or lost SIM and notification of death of end-user. PTEs must ensure the security and confidentiality of information gathered and comply with the Data Privacy Act and related issuances at all times.

PTEs are also protected from administrative, civil, or criminal liability arising from its disclosure of confidential information to a competent authority in relation to an investigation that a specific mobile number was being used in the commission of  a crime and that the perpetrator’s identity cannot be ascertained.

Punishable acts, such as providing false or fictitious information or identities, selling of SIM without required registration, spoofing of registered SIM, carry penalties of imprisonment ranging from six months to six years and/or a fine for up to PHP 4 million pesos.

Why SIM Registration Act IRR is important

With the call of legislators and various politicians for the release of the SIM Registration Act IRR, all SIM users – individuals, companies, and foreigners alike – must be mindful that they preliminarily have until 28 April 2023 to register their SIM cards pursuant to the law and the IRR to ensure continued use of PTE services. The deadline to register the SIM may be extended for another 120 days. Businesses that rely on mobile phones and/or provide company SIMs to their employees must comply with the PTE registration for continued services to their employees. Disruption of business activities in case of other SIM end-users’ failure to register may also be expected. PTEs are expected to roll out their respective registration processes for compliance with the Act and the IRR in the coming days.

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Bienvenido Marquez III is a partner and head of Quisumbing Torres' Intellectual Property, Data and Technology Practice Group. He also co-heads the Consumer Goods & Retail Industry Group and is a member of the Technology, Media & Telecommunications Group. He participates in initiatives of Baker & McKenzie International of which Quisumbing Torres is a member firm. He is a member of Baker McKenzie's Asia Pacific Intellectual Property Steering Committee and the Asia Pacific Intellectual Property Business Unit for Brand Enforcement. He is immediate Past President of the Philippine Chapter of the Licensing Executives Society International (2019-2021), and is currently co-chair of the LESI Asia Pacific. He is also a member of the Anti-Counterfeiting Committee of the International Trademarks Association (INTA). Bien has vast experience in handling IP enforcement litigation, trademark and patent prosecution and maintenance, copyright, data privacy, information security, IT, telecommunications, e-commerce, electronic transactions, cyber security and cybercrime. He has been consistently ranked as a leading individual for Intellectual Property and TMT in Legal 500 Asia Pacific, Chambers Asia Pacific, asialaw Leading Lawyers, Managing IP Stars, Asia IP, and World Trademark Review. He was also recognized as a Volunteer Service Awardee by INTA in 2018.


Divina Ilas-Panganiban is a partner in Quisumbing Torres’ Intellectual Property, Data and Technology Practice Group and co-heads the Technology, Media & Telecommunications (TMT) Industry Group. She participates in initiatives of Baker & McKenzie International of which Quisumbing Torres is a member firm. She is a member of Baker & McKenzie International's Asia Pacific TMT Steering Committee. She currently serves as the Vice-President and Director of the Philippine Chapter of the Licensing Executives Society International, the Chairperson of the Committee on Intellectual Property Rights, The American Chamber of Commerce of the Philippines, and the Chairperson of the Committee on Intellectual Property Rights of the European Chamber of Commerce. Divina heads the Subcommittee for East Asia and the Pacific of the Unreal Campaign of the International Trademarks Association (INTA) and is a Certified Information Privacy Manager by the International Association of Privacy Professionals (IAPP).


Reena Mitra-Ventanilla is a partner in Quisumbing Torres’ Intellectual Property, Data and Technology Practice Group. She is a member of the Consumer Goods & Retail and Financial Institutions Industry Groups. She has 13 years of experience handling intellectual property and technology matters. She is currently the corporate secretary of the Philippine Chapter of the Licensing Executives Society International and the assistant corporate secretary of the Philippine Franchise Association. Reena is recently cited as a Next Generation Partner in Intellectual Property by the Legal 500 Asia Pacific 2021.


Frederick August Jose, CIPP/E is a senior associate in Quisumbing Torres’ Intellectual Property, Data and Technology Practice Group and Technology, Media & Telecommunications. He has 10 years of experience in a wide range of IP and IT corporate and litigation matters.

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