It is key for M2M applications that they can be provided globally on the basis of SIM cards that are embedded in the respective M2M equipment. The global connectivity enabling such global M2M offers is generally provided on the basis of so called "permanent roaming", using the numbering resources of a single mobile provider which are often assigned by a specific jurisdiction. One type of numbering resources commonly used for the provision of M2M services are mobile phone numbers (i.e. mobile numbers based on ITU-T Recommendation E.164.) As a rule, the use of foreign numbers (this includes E.164 numbers as well as IMSI numbers according to ITUT Recommendation E.212 for the provision of electronic communication services is forbidden in Germany, unless such use is in the context of temporary international roaming. This so called "exterritorial use" of foreign phone numbers (not limited to mobile numbers) has now been expressly permitted by the German Regulator, the Federal Network Agency ("BNetzA") for M2M communications (Order 80/2017, Official Gazette 16/2017 of 23 August 2017, the "Order"). The Order will apply with effect from 23 November 2017. BNetzA defines the term "M2M communication" as "automated exchange of information between technical installations such as, among other things, machines, automatons, vehicles or measuring devices or between such installations and a centralized data processing system." The Order applies this concept broadly so that while as a rule, humans are not involved in such communication, a limited human participation does not preclude a service from being considered M2M communication if the communication is predominantly between machines. Examples of M2M communications are the activation or operation of M2M applications or the activation of applications enabling individual communications but only as predefined point-to-point communication (e.g. in case emergency calls in vehicles or elevators). The permissibility of the exterritorial use of foreign phone numbers for M2M communications is subject to the notification of such use to BNetzA. The notification needs to be filed by the entity who has been assigned the numbers to be used by a foreign regulatory authority. The notification requirement also applies to existing exterritorial usage of foreign numbers - the Order does not grandfather existing applications. BNetzA considers the notification requirement necessary for reasons of public security. BNetzA expressly notes that their permission of an exterritorial use of foreign phone numbers in Germany does not affect the question whether or not such use is permitted under the laws of the country where the numbers were assigned. With separate order (Order 78/2017, Official Gazette 16/2017 of 23 August 2017) implementing changes to the Numbering Plan for Numbers for Mobile Services effective from 23 November 2017 (a consolidated version of the Numbering Plan as of 23 November 2017 is available here), an exterritorial use of German mobile numbers for M2M communications outside of Germany is permitted as well (again, subject to a notification requirement). Following its orders to permit the exterritorial use of IMSI for M2M communication in 2016, BNetzA has now taken the next step to support and facilitate the provision of M2M services. It remains to be seen whether the notification requirement - in particular where it is applied retroactively - proves to be a significant hurdle for the global provision of M2M services as stated by a number of participants to the public consultation BNetzA has conducted (a summary of the contributions as well as BNetzA's comments to the contributions is available here). In any case, BNetzA's practice to provide for a general permission regarding the exterritorial 2 use of numbers for M2M communication underlines its commitment to support the provision of innovative services in Germany.