As the Government of Ghana intensifies its drives to issue the national identity card – also known as the Ghana Card – to all citizens and residents and to re-register all SIM cards using the Ghana Card, the National Communications Authority (“NCA”) recently issued a press release in which it announced imminent service interruptions for unregistered SIMs. This follows the extension of the SIM registration deadline from 31 July 2022 to 30 September 2022.

In order to re-register a SIM, one must:

1) obtain a Ghana Card through the National Identification Authority (“NIA”);

2) complete an initial self-registration by linking the Ghana Card number through a short code by phone; and

3) personally visit the office of the mobile network operator with the Ghana Card in order to capture biometric data. A self-service application accessible through the Google Play Store was also launched last week as an alternative to visiting mobile network operators for final registration step, although its success to date has not been reported.

On the punitive measures, the NCA has set the following to last for the month of September:

· Starting today, 5 September 2022, unregistered SIMs will be divided into five (5) groups, each of which will have outgoing calls blocked rotationally for two (2) days once a week.

· In addition, mobile subscribers who have not begun the second step of the registration process will be re-routed to a recorded message sensitizing them on registration before they are connected to outgoing calls.

· From 7 September 2022, those who have linked their Ghana Card numbers through the short code but have not completed the biometric registration will also be re-routed to the recording before being able to connect to outgoing calls.

· From 12 September 2022, data services will be blocked on the same rotational basis described for outgoing calls above.

· Text messaging will not be blocked.

After 30 September 2022, the NCA has directed mobile network operators as well as broadband wireless access players such as Surfline to deactivate all SIMs not fully registered. There will however be a six (6) month period in which subscribers may

complete registration to redeem their SIMs; after that point, SIMs will be placed in a pool for onward reassignment.

Given the multi-step process typically involving multiple in-person visits and underpinned by NIA delays in issuing the prerequisite Ghana Card, SIM deactivation after 30 September 2022 is likely to displace Ghanaians as far as telecommunications and payment services – a significant step backward in the Government’s digitalization agenda. While mass SIM re-registration is crucial to preventing fraud and other criminal activity, it is essential that the NCA coordinate deadlines and subsequent sanctions with the NIA on an informed basis, tracking daily statistics of Ghana Card uptake and investigating sincere challenges associated with it.

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