Ten years after its introduction, the embedded Sim (eSim) has been most transformative when used when travelling, according to a new global industry survey – a finding that carries awkward implications for South Africa’s Sim-registration regime.

The Mobile World Live eSim Survey Report 2026, produced in partnership with 1Global, Amdocs and Kigen, found that 55% of mobile industry insiders cite travel as the primary eSim consumer use case, second only to new phone setup. GSMA Intelligence research cited in the report shows 60% of eSim users globally had used the technology while travelling abroad in the previous 12 months.

“For now, eSim is making the biggest difference in the travel sector, where consumers are attracted by the low cost and on-boarding convenience of eSim. eSim enables simplified global service delivery, reduced operational complexity, faster time to market, and new commercial models across channels and geographies,” 1Global said in the report.

The ability to provision an eSim remotely lets travellers load and activate a destination Sim before leaving home, and pricing has fallen sharply as a result.

MTN’s low-cost telecoms service Pi has a partnership with Nomad eSim that offers visitors to South Africa a seven-day, 1GB plan for R67 and a 30-day, 5GB plan for R183. For South Africans travelling abroad, a 30-day 5GB US eSim costs R216, while Etravelsim’s 30-day 25GB plan goes for US$21.99 (R366).

But the same convenience that makes eSims attractive to travellers exposes a gap in South Africa’s Sim-registration regime – one that did not exist when the underlying law was drafted.

Rica requirements

Under the Regulation of Interception of Communications and Provision of Communication-Related Information Act (Rica), South Africans must register their full name, identity number and address with a licensed network operator before activating any Sim.

Section 40(1)(b) exempts foreign travellers on temporary connections from the requirement. But the Sim-registration regime, introduced via the 2008 Rica amendments and brought into force on 1 July 2009, did not contemplate a world in which a consumer could install a globally provisioned eSim profile from a foreign provider in seconds, with no interaction with a South African operator.

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International providers including Airalo, Saily, Yesim and Etravelsim openly market the workaround on their South African landing pages. Etravelsim tells customers its South African eSim “avoids Rica registration entirely”. SimCorner markets its product as one that “bypasses the complex Rica document requirements”.

Two distinct problems flow from this. The first is administrative: foreign travellers buying South African eSims sidestep a process they were already exempt from in principle but rarely able to navigate in practice. The second is more serious – South African residents can acquire untraceable, anonymously activated connections for use inside the country, undermining the crime-prevention purpose that justified Sim registration in the first place.

Justice & constitutional development minister Mmamoloko Kubayi

Luyanda Maema, legal intern at PPM Attorneys, said Rica places the registration obligation on the provider rather than the consumer. “The drafting is framed in a way that prohibits service providers from activating or selling Sims without collecting and verifying the requisite personal information,” Maema said. The difficulty is that foreign providers fall outside that net.

International precedent for closing the gap exists. Brazil’s communications regulator, Anatel, ruled in September 2025 that eSim provisioning constitutes a core telecommunications function and that any company offering it must hold an MVNO (mobile virtual network operator) licence – effectively shutting the foreign eSim loophole there.

In South Africa, justice & constitutional development minister Mmamoloko Kubayi convened an urgent meeting on 26 March with telecoms CEOs and regulators on Rica enforcement, with a crackdown on fraudulent Sim registrations due to begin on 1 July. Penalties of up to R5-million and 10 years’ imprisonment already exist in law. The department acknowledged in a statement after the meeting that the framework must “keep pace with technological developments, including the emergence of eSim technologies”, but the public-facing focus has remained on bulk-registered physical Sims sold through informal channels.

‘More complex’

Nomvuyiso Batyi, CEO of telecoms industry lobby group the Association of Comms & Technology, said there is a policy argument that international eSim purchases used inside South Africa should comply with Rica, but legislating it is “more complex than applying existing Sim registration rules to local operators”.

Read: eSims: a threat to mobile operators?

“The challenge with international eSim providers is that they often operate outside South Africa’s jurisdiction. Many provide data-only services without South African numbering resources and may not perform identity verification in line with Rica,” Batyi said. “Strict rules may impact tourism, business travel and cross-border commerce.” – © 2026 NewsCentral Media