Précis  Ofcom has published a report it has commissioned into the technology, evolution and likely implications of the use of reprogrammable Subscriber Identity Modules ("SIMs") for consumers and stakeholders.  Reprogrammable SIMs would enable a change of mobile service provider without having to change SIMs.

What?  SIMs are a core element of the mobile communications system and can be traced back to the original conception and formation of the Global System for Mobile communications ("GSM").  Since then the SIMs have evolved both in functionality and physical size.  Now new applications for mobile communications services, like machine-to-machine ("M2M") technology, have sparked interest in enabling SIMs to be reprogrammed rather than discarded when changing mobile service provider.

So what?  There has been much interest recently in the concept of embedded or reprogrammable SIMS.  The most high profile was when Apple announced in 2010 that, as part of the iPhone development, it was working on an embedded reprogrammable SIM which would allow consumers to buy a phone online or at the Apple Store, with all activations taking place via Apple's App Store (and thereby bypassing the mobile network operator ("MNO") entirely).  Since then the idea has been accepted by the GSM Association with the release of a specification for future use of reprogrammable SIMs.

What is a reprogrammable SIM?

Traditional SIMs are standalone elements of the GSM systems that are distributed and, in the UK at least, provided by each MNO.  These SIMs are prepared and customised for each particular MNO by a selected number of manufacturers.  SIMS undertake a number of crucial tasks in mobile networks, from the mundane such as holding contact details to critical tasks such as authentication and encryption of a voice/data call.  However each element is effectively hard wired at the point of manufacture of the SIM.  A reprogrammable SIM performs the same functionality, but has the added benefit in that it can be changed at will without the need to physically change a SIM card.  At the time of this briefing, a reprogrammable SIM function can be implemented in two ways: (i) a software SIM function that is implemented in code only or (ii) by means of a reprogrammable SIM circuit/chip that is hardwired into a device at the point of manufacture and which is then reprogrammed as and when required by a specialist, such as the manufacturer, the MNO or a trusted third party.  Manufacturers currently appear to be favouring the hardwired approach.

Why is this important?

This is important for a number of reason, primarily because it would negate the input that MNOs and SIM manufacturers have in the process and in effect gives greater power to the device manufacturers.  There is also a manufacturing benefit in that the devices can be made smaller and thinner as it would negate the need for a physical card to be inserted into any device.

Why is the debate taking place now?

The debate has been triggered by the fact that there are now more and more M2M interfaces and connections taking place over the mobile networks, partly led by development such as metering, sensor development and other such forms of automation.  Should a user wish to change networks, a reprogrammable SIM would negate the current need to remove the SIM card from each device that connects to a mobile network and replace it, as the change could be implemented remotely over the air.

The report commissioned by Ofcom has identified the following key benefits for the stakeholders identified above:

  • SIM manufacturers could have a greater role in the activation market and thereby generate new revenue streams;
  • MNOs may be able to take a leading role in the developing M2M market by offering new M2M products and solutions (for example in so-called 'smart metering' and other forms of automation);  
  • M2M manufacturers will be able to manufacture and distribute devices around the world with the ability to activate devices after they have been shipped; and
  • for consumers it could result in reduced costs in the form of cheaper tariffs, simpler and easier international swapping while roaming, and also more effective selection of networks and tariffs depending on location, the service being used (date or voice) and also as to the quality of the mobile network connection/reception.

What are the likely short term outcomes?

Reprogrammable SIMs are unlikely to impact on consumers in the short term as the current focus appears to be in relation to M2M devices.  Reprogrammable SIMS will have an impact on consumers in the long term but is entirely dependent on how quickly handset manufactures implement such functionality in their devices.  The purpose of the Ofcom report seems to be to bring the debate into the general arena.  While the report outlines a number of solutions for implementing a reprogrammable SIM functionality, it is likely that manufactures, MNOs and regulators would implement solutions that are tailored to their specific requirements.

Please click here to read the report prepared for Ofcom.