I. Introduction

The Subscriber Identity Module (SIM) Registration Act, officially Republic Act No. 11934, took effect on December 27, 2022, and was implemented under the Department of Information and Communications Technology (DICT), with the National Telecommunications Commission (NTC) as the regulatory body. The law aims to curb criminal activities such as scams, fraud, and terrorism by ensuring that all SIM cards are registered to verified users.

An integral part of this legal framework is the reactivation and replacement process of SIM cards — a crucial subject that determines how subscribers can recover their numbers or replace lost, damaged, or deactivated SIMs within the confines of the law.

II. Legal Framework for SIM Reactivation and Replacement

A. Coverage and Purpose

Under the SIM Registration Act and its Implementing Rules and Regulations (IRR), all SIM cards, whether prepaid, postpaid, or embedded (eSIM), are required to be registered under the name of the end-user. The law mandates telecommunication companies (telcos) such as Globe Telecom, Smart Communications, and DITO Telecommunity to establish clear and secure procedures for:

Reactivation of deactivated SIMs, and
Replacement of lost, damaged, or stolen SIMs.

The law provides that only legitimate, verified subscribers may avail themselves of these services.

III. SIM Card Reactivation Rules

A. Grounds for Deactivation

SIM deactivation may occur under the following circumstances:

Non-registration within the period set by law (initially 180 days, extendable by DICT);
Voluntary deactivation by the user;
Administrative or network-related suspension by the telco for violations of terms of service or fraudulent use; or
Loss or theft of device or SIM, leading to user-requested blocking.

B. Reactivation Procedures

Under the IRR and telco-specific policies approved by the NTC:

For SIMs deactivated due to late registration:
- Once permanently deactivated after the registration deadline, the SIM number cannot be reactivated.
- The subscriber must purchase a new SIM and register it anew.
For voluntarily deactivated or temporarily suspended SIMs:
- The subscriber may request reactivation through official telco channels, subject to identity verification using valid government-issued IDs and subscriber information that matches the original registration record.
For temporarily deactivated postpaid accounts:
- Reactivation may be allowed once billing issues or contractual violations are resolved, and subject to the telco’s internal policies consistent with the SIM Registration Act.

C. Reactivation Timeline and Limits

Telcos must provide reasonable timeframes for processing reactivation requests, generally within 24 to 72 hours upon submission of complete requirements.
However, permanent deactivation (for unregistered SIMs after the final registration deadline) is irreversible, and the mobile number is forfeited.

IV. SIM Card Replacement Rules

A. Circumstances Warranting Replacement

A SIM card replacement is permitted under the following:

Loss or theft of the mobile device or SIM;
Physical or technical damage to the SIM;
Malfunctioning SIM due to network or manufacturing defects;
Upgrade to a different SIM format or technology (e.g., eSIM migration).

B. Replacement Requirements

The following general requirements apply for SIM replacement:

Proof of identity — a valid government-issued ID used during the initial SIM registration;
Affidavit of loss (for lost or stolen SIMs);
Police blotter or incident report (for cases involving theft or fraud); and
Customer verification process via telco service center, online portal, or authorized agent.

If the SIM was originally registered under a corporate or institutional name, an authorization letter and company ID of the authorized representative** are additionally required.

C. Number Retention and Data Privacy

When a SIM is replaced, the mobile number remains the same, provided the request is valid and verified. The telco must ensure that personal data and account credentials are transferred securely, complying with the Data Privacy Act of 2012 (Republic Act No. 10173).

Unauthorized replacement — especially using falsified documents — constitutes a criminal offense under the SIM Registration Act, punishable by imprisonment and fines.

V. Role of the National Telecommunications Commission (NTC)

The NTC oversees compliance with the SIM Registration Act. Its powers include:

Issuing directives and guidelines on SIM reactivation and replacement procedures;
Conducting audits and inspections of telco systems;
Imposing sanctions or penalties for non-compliance or data breaches; and
Coordinating with the National Privacy Commission (NPC) in cases of identity theft or misuse of registered data.

The NTC may require telcos to maintain records of reactivation and replacement transactions for regulatory monitoring and investigation.

VI. Penalties and Liabilities

The SIM Registration Act imposes strict penalties for violations, including:

Use of false identities or forged documents in SIM reactivation or replacement;
Impersonation of registered subscribers;
Negligence by telcos in verifying user identity; and
Unauthorized disclosure of personal data.

Violators may face:

Imprisonment of up to six (6) years, and/or
Fines ranging from ₱100,000 to ₱1,000,000, depending on the gravity of the offense.

VII. Consumer Protection and Remedies

Subscribers who encounter wrongful deactivation, denial of legitimate reactivation, or unauthorized replacement may file complaints before:

The NTC Regional Office with jurisdiction over the area; or
The National Privacy Commission, if the matter involves personal data breaches.

Telcos are mandated to provide accessible hotlines, online portals, and service desks to address SIM-related concerns.

VIII. Conclusion

The SIM Registration Act establishes a stringent yet necessary framework for the reactivation and replacement of SIM cards in the Philippines. It seeks to balance national security, consumer protection, and privacy rights, ensuring that all SIM-related activities occur within lawful, verifiable, and transparent processes.

For consumers, the most critical takeaway is to ensure that:

Their SIMs are properly registered under their true identity;
They safeguard registration details and ID copies used in the process; and
They comply with verification requirements when seeking reactivation or replacement.

These safeguards not only protect individual users but also fortify the country’s collective defense against digital crimes.