SIM Registration Authorization Requirements in the Philippines
A practitioner-oriented legal overview (updated 17 May 2025)
1. Statutory & Regulatory Framework
| Instrument | Date | Key points |
|---|---|---|
| Republic Act No. 11934 (“SIM Registration Act”) | Signed 10 Oct 2022; in force 27 Dec 2022 | Establishes the obligation to register all SIMs (pre-paid & post-paid) before activation and retroactively for existing subscribers (Wikipedia) |
| NTC Memorandum Circular No. 001-12-2022 (Implementing Rules & Regulations, “IRR”) | Issued 12 Dec 2022; took effect 27 Dec 2022 | Details the documentary, procedural and security requirements for registration, deactivation, data retention and disclosure (Jur.ph) |
The IRR fixed an initial 180-day registration window (27 Dec 2022 – 25 Jun 2023), extended once by 90 days to 25 Jul 2023, after which a five-day grace period elapsed and unregistered SIMs were permanently de-activated. (Panay News) As of 30 Jul 2023, 113.97 million SIMs (≈ 68 %) were registered and 54 million were de-activated. (Wikipedia)
2. Who Must Register
The obligation covers “end-users” — natural or juridical persons “purchasing and/or using” a SIM sold by a Philippine Public Telecommunications Entity (PTE), its agents or resellers. It also applies to:
- Embedded/IoT SIMs in devices sold locally;
- e-SIMs activated on Philippine networks;
- SIMs issued for machine-to-machine (M2M) applications if provisioned with a public MSISDN.
3. Authorization & Documentary Requirements
| End-user category | Authorized registrant | Mandatory documents* |
|---|---|---|
| Individuals (18 y/o ↑) | The subscriber themself | ① Duly accomplished electronic form (full name, DOB, sex, address, ID type & number); ② ONE valid, photo-bearing gov’t ID (passport, PhilSys ID, driver’s licence, UMID, PRC ID, etc.). (cavitedigitalmarketing.com) |
| Minors (< 18 y/o) | Parent or legal guardian registers in their own name | (a) the parent/guardian’s valid ID; and (b) written consent to register the child’s SIM. (cavitedigitalmarketing.com, Panay News) |
| Juridical persons (companies, NGOs, gov’t agencies) | Authorized representative | (a) SEC/DTI/CDA Certificate of Registration; (b) Board resolution or Special Power of Attorney naming the representative; (c) representative’s valid ID. (cavitedigitalmarketing.com) |
| Foreign nationals | The foreign subscriber | Tourists (≤ 30 days) – passport, proof of PH address, return/onward ticket (SIM auto-expires with visa). Other visa types – passport, proof of address, plus visa-specific docs (e.g., ACR-I Card, Alien Employment Permit, school registration). (cavitedigitalmarketing.com, Jur.ph) |
* Originals or high-resolution scans are uploaded to the PTE portal; face-to-face or assisted registration is available in LGU-hosted booths for users without internet or with disabilities. (Panay News)
4. Special Compliance Situations
| Scenario | Rule |
|---|---|
| Multiple SIMs | Each SIM must be registered individually under the same owner; no statutory cap on quantity. |
| Transfer or sale of a registered SIM | Permitted only after the buyer completes a new registration with the PTE. The current owner must request transfer-of-ownership through the PTE, which will verify identities and update the SIM Register. Unauthorized sale or trafficking of pre-registered SIMs incurs criminal liability. (cavitedigitalmarketing.com) |
| Lost, stolen, or compromised SIM | Holder must report to the PTE within 24 h. The SIM is suspended or de-activated; replacement requires re-registration. |
| Change of information | Registrants must update any change (address, ID, legal name) within 30 days via the PTE portal. |
5. Data Governance & Law-Enforcement Access
Retention – PTEs must store registration data for the life of the SIM + 10 years from de-activation, under ISO-certified security controls and RA 10173 (Data Privacy Act) standards. (Jur.ph)
Confidentiality – Disclosure is strictly limited to:
- A duly issued subpoena or court order; or
- A written request from a law-enforcement agency in a case involving an “immediate risk, imminent danger, or loss of life.” (The Manila Times, Jur.ph)
Audit – NTC may conduct compliance inspections; NPC may investigate privacy breaches.
6. Penalties for Non-Compliance (selected)*
| Violation | Fine | Imprisonment |
|---|---|---|
| False/fictitious info or ID | ₱100 k – ₱300 k | 6 mo – 2 yrs |
| Selling a registered SIM without proper transfer | ₱100 k – ₱1 m | 6 mo – 6 yrs |
| Telco failure/refusal to register | ₱100 k – ₱1 m per offense | — |
| Breach of confidentiality (willful) | ₱500 k – ₱4 m | — |
* Courts may impose both fine and imprisonment; accessories include confiscation of offending SIMs and revocation of telco licences in extreme cases.
7. Institutional Roles
- NTC – primary regulator; issues circulars, monitors PTE databases, imposes administrative fines.
- DICT – overall policy coordination; may extend deadlines and direct nationwide assisted-registration drives.
- DILG & LGUs – grassroots information campaigns and registration centres, especially in geographically isolated areas. (Panay News)
- NPC – oversees personal-data processing and investigates breaches.
- PNP/NBI/CICC – request data in pursuit of cyber-crime investigations under the disclosure rules above.
8. Litigation & Policy Review
On 17 Apr 2023 media and rights groups asked the Supreme Court to void RA 11934 for alleged over-breadth and privacy violations. The Court denied a TRO but required government agencies to justify constitutionality; the petition remains pending. (Wikipedia)
Congressional committees are studying amendments to refine data-privacy safeguards and add biometric verification for high-risk transactions. No bill has yet progressed beyond committee as of May 2025.
9. Practitioner’s Compliance Checklist
- Gather proper ID – verify that scans/photos are clear and unaltered.
- Confirm authority – board resolution or SPA for corporate/agency SIMs; parental consent for minors.
- Use the official portal – avoid third-party links; check for the “.ph” domain and HTTPS.
- Retain proof – download or screenshot the portal confirmation page and reference number.
- Update logs – for entities issuing pooled SIMs, keep an up-to-date user roster mapped to each SIM/IMEI.
- Prepare for audits – ensure that privacy notices, security policies, and internal procedures align with the Data Privacy Act and the IRR.
10. Key Take-aways
The SIM Registration regime is document-heavy but not unduly cumbersome if the correct authorizations are prepared in advance. For lawyers and compliance officers, the critical tasks are (a) verifying the identity and authority of the registrant, (b) safeguarding collected data, and (c) establishing workflows for transfer or de-activation events.
While early technical glitches and privacy concerns persist, the law has already cut anonymous mobile numbers by one-third, giving law-enforcement a clearer trail for scam-related probes. Continuous monitoring of the pending Supreme Court case and any amending legislation is essential to stay ahead of further compliance adjustments.