Germany - BNetzA permits extraterritorial use of IMSI for M2M communication
In June 2016, BNetzA's new rules regarding the use of foreign International Mobile Subscriber
Identities (IMSI) for Machine-to-Machine (M2M) communications became effective.
According to the new rules, an extraterritorial use of German IMSI abroad for M2M communications
and an extraterritorial use of foreign IMSI in Germany for M2M communications are now generally
permitted. This is crucial for the economic and technical feasibility of most M2M services which
usually require global connectivity. Such connectivity is usually provided making use of a so called
"global" SIM card (equipped with the IMSI and possibly the mobile number of a connectivity provider)
and based on the international roaming agreements established by the connectivity provider.
BNetzA has applied a classification of M2M services which goes beyond a mere communication
between machines and which includes "limited human participation". This leads to a quite broad
scope of services to be considered M2M communication including the activation or operation of M2M
applications by means of a computer, smartphone, tablet, etc., as well as applications that enable
e.g., eCall in vehicles, private emergency calls in elevators or vehicles or concierge services in
In the future, BNetzA intends to also regulate the extraterritorial use of mobile numbers (i.e., E.164
numbers) for M2M communications by way of amending the numbering plan for Mobile Services and
passing a new Order regarding foreign E.164 numbers. BNetzA will conduct a separate consultation
regarding these planned amendments.
BNetzA's decision is a consequent step in BNetzA's strategy to support and facilitate the provision of
M2M services in Germany.
For more information, please contact Joachim Scherer or Caroline Heinickel.