Search for:

In brief

From 31 January 2023, the Info-Communications Media Development Authority (IMDA) implemented the full SSIR regime. All organisations that use short message service (SMS) with sender identification (“Sender ID“) are required to register their Sender IDs with the Singapore SMS Sender ID Registry (SSIR). Non-registered SMSes have been labelled as “Likely-SCAM” and will be blocked from later this year. Organisations are encouraged to register their Sender IDs if they have not done so.


In depth

Scope of the SSIR

Organisations sending SMSes originating locally and overseas to Singapore mobile users that utilise Sender IDs, including application-to-person (A2P) messaging, are required to register with the SSIR. Telecommunication operators are also required to register their SMS Sender IDs with the SSIR. However, person-to-person (P2P) SMSes, which are SIM-based and sent via SIM cards where the Sender ID is tied to a unique mobile number, will not need to be registered.

These additional anti-scam measures came into force on 31 January 2023. SMSes with unregistered Sender IDs are now channelled through the Sender ID “Likely-SCAM”, which functions similarly to a spam filter and spam bin. Consumers are advised to exercise caution when receiving such SMSes. This is an example of what a “Likely-SCAM” SMS looks like:

CASE1833016

The “Likely-SCAM” Sender ID will only be available for around six months. After that, all SMSes with unregistered Sender IDs will be blocked.

There have been some teething issues in the implementation of these additional measures. Numeric A2P SMS are also blocked even though they are not strictly alphanumeric sender IDs such as “My Brand”. To continue using numeric Sender IDs such as short code sender IDs (e.g., 7XXXX) and Long Virtual Number (LVN) Sender IDs (e.g., 8XXXXXXX and/or 9XXXXXXX), an organisation will need to submit supporting document(s) to the SSIR showing that the short code and/or the LVN sender ID was issued by a mobile network operator in Singapore to the organisation’s SMS aggregator. The short code and/or the LVN sender ID will also need to be unique to the organisation.

For LVN Sender IDs, only LVNs from the 8 and 9 series can be registered. The organisation should also register both the 10-digit LVN with the “65” prefix (e.g., 658XXXXXXX and/or 659XXXXXXX) and the 8-digit LVN (e.g., 8XXXXXXX and/or 9XXXXXXX). The two versions of the LVN will be considered as one Sender ID for billing purposes.

Registration

Organisations that wish to send SMS with Sender IDs to Singapore mobile users must:

  • Register Sender IDs with the SSIR
  • Only use aggregators who participate in the SSIR

Registration with SSIR will require a Singapore local unique entity number (UEN). While it is acknowledged that foreign companies may not have UENs, they can obtain a Singapore UEN by registering with the Accounting and Corporate Regulatory Authority, either by incorporating a local subsidiary (having the local subsidiary register the Sender ID using its UEN) or registering a foreign branch office.

Organisations can authorise their overseas affiliates to send SMSes with registered Sender IDs on their behalf. This will require a letter of authorisation from the organisation to be provided to the SMS aggregator licensed by the IMDA.

Assignment priority

Organisations sending SMSes with Sender IDs will need to choose SMS aggregators who are licensed by the IMDA and registered with the SSIR to send SMSes to Singapore mobile users. The SSIR will assign Sender IDs on a first-come-first-served basis and may clarify with registrants if they have a trademark or other legitimate claim to the Sender ID.

* * * * *

For further information and to discuss what this development might mean for you, please get in touch with your usual Baker McKenzie contact.

LOGO_Wong&Leow_Singapore

© 2023 Baker & McKenzie.Wong & Leow. All rights reserved. Baker & McKenzie.Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a “principal” means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an “office” means an office of any such law firm. This may qualify as “Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.

Author

Andy Leck is the head of the Intellectual Property and Technology (IPTech) Practice Group and a member of the Dispute Resolution Practice Group in Singapore. He is a core member of Baker McKenzie's regional IP practice and also leads the Myanmar IP Practice Group. Andy is recognised by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal 2018. In addition, Chambers Asia Pacific notes that Andy is "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear disputes at IPOS for a two-year term from April 2021. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center. He is also appointed as a Notary Public & Commissioner for Oaths in Singapore. He previously served on the International Trademark Association’s Board of Directors and was a member of the executive committee.

Author

Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

Author

Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is regularly ranked as a leading TMT and competition lawyer by top legal directories, including Chambers Asia Pacific and Legal 500 Asia Pacific. Ken is an IAPP Certified International Privacy Professional (FIP, CIPP(A), CIPT, CIPM) and a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators.

Write A Comment