Holland says yes to the network-agnostic SIM card


Credit: Shutterstock / Albert Lozano

Regulators in Netherlands this week opened the door for any company — whether Apple, Audi or your local electric utility — to issue its own SIM cards configured to no particular carrier. This is just one country changing its rules, but if other countries follow suit, it could have big implications for the internet of things and even change the way we buy mobile service.

A few years ago in a Gigaom post, European economist and policy analyst Rudolf van der Berg explained how such a setup could work for Apple(s aap) if it chose to shed the carrier yoke and sell connectivity directly to its iPhone customers. Basically Apple would provide SIM cards to all of its customers, and then remotely assign them different carrier networks as customers activated their service.

SIM cards galore

Source: Flickr / mroach

Apple could buy data and voice services in bulk from hundreds of different carriers around the world and then pick which network would be most appropriate for each of its customers at any given time. So if an iPhone user left his home country for a vacation in France, for instance, he wouldn’t get charged the usual high roaming rates. Instead Apple would just reassign his SIM card to one of the French networks. Instead of being a guest roaming onto a French carrier’s networks, he’d be at “home” anywhere in the world.

Whether an Apple or a Samsung has any interest in becoming a carrier to its customers remains to be seen — back in 2010, Gigaom reported that Apple was working on such a soft-SIM, though nothing seemed to come of it — but it could be of enormous use in the machine-to-machine (M2M) communications world, van der Berg told me in an email exchange this week.

Take a car company like GM, which is putting LTE connectivity into all of its cars. In the U.S., GM is locked down to a single operator. It doesn’t matter if you buy your smartphone plan from Verizon(s vz) or T-Mobile(s tmus); if you want to connect your Chevy to an LTE network, you have one choice: AT&T(s t).

With a carrier agnostic-SIM, a carmaker could attach your car to whatever carrier to you happen to have relationship with and change your connection whenever you switched carriers. Or it could run a managed service with multiple carriers, connecting to whomever’s network had the best capacity or coverage wherever you happened to be driving, said van der Berg, who is now with the Organisation for Economic Co-operation and Development (OECD).

Source: Gigaom

Source: Gigaom

While some carriers might be opposed to that concept, the mobile industry overall would benefit, van Berg said. In the internet of things, there is a lot of resistance to connecting gadgets and appliances to the cellular network because doing so would require device makers to lock into a carrier. But a programmable SIM card would alleviate that burden, making cellular connectivity much more attractive, van der Berg said.

Of course, we’re still a long way from this kind of carrier-agnostic networking become a reality. The Netherlands has eased its rules, and the GSM Association is behind the concept, but the network-less SIM is still illegal in almost every country in the world, van der Berg said.

And even with legal barriers lifted in Holland, there are technical limitations that need to be overcome, van Berg said. Still, getting Dutch regulators on board was a big victory, setting an example that van der Berg hopes other governments will follow.

Correction: This post previously stated that a network-agnostic SIM is also legal in the U.S. and Germany. That’s the not the case. It is allowed only in the Netherlands.



Till the regulators around the globe will joined these positive approach, there are solution based on a technology approach.

A start-up form Israel (simgo-mobile) showing its face for the first time last month in Barcelona Mobile World Congress, show exactly these, they had developed the ability to virtually switch SIM cards in any mobile device including smart phones like Samsung Galaxy and iPhone.

So when ever a need arise to switch SIM/ Carrier its been done in a push of a button, so both a person traveling or the car can be free from the dependence of the mobile operator.

I’m sure that what the Holland regulators are pushing to might be better but until the world will join them there are technological ways to overcome these issues.

Bettina Rubek Slater

Eseye has been supplying managed M2M connectivity with true OTA reprogrammable Multi IMSI SIM cards since 2013 and we have hundreds of customers using them.

The challenge we were solving with the Multi IMSI cards were exactly as described above – eliminating the risk of stranded devices in their tens or hundreds of thousands. Through our partnerships and with our own proprietary IMSI management application we are able to re-provision IMSIs OTA on the cards during lifetime deployment. Our AnyNet SIM cards have up to 99 SIM slots and we always have a fall-back provision to our roaming IMSI which means the SIM card is never without identity and as such it is legal.

See more here: http://www.eseye.com/products-and-services/eseye-m2m-products-devices.html

I am happy to chat to anyone who would like to know more.

Podsystem M2M

Abhay, you are correct, what we are aiming to do with the multi-IMSI solution is put the control back into the hands of the customer. In this case, the customer owns the SIM card, we negotiate with multiple global networks to include the IMSIs, but the customer has ultimate control about what IMSI the SIM is roaming on, we can even provide the customer with the OTA commands to include their own IMSIs if they wish. Please see http://www.podsystem.com/the-company/our-vision-and-strategy for more info.

Michel Zwijnenberg

We are a Dutch based M2M MVNE and were involved in answering the question how to achieve M2M SIM-card portability.

We are happy to discuss with any company considering to register for their own MNC.

Taken into account the EU law on roaming per 1-7-2014, a M2M SIM registered in only one EU country is sufficient to cover the whole of the EU.

Michel Zwijnenberg (ASPIDERM2M)

Rudolf van der Berg

Abhay, multi IMSI is a technical hack to fix a regulatory problem. Multi-IMSI and eUICC or a combination of both, put an operator in charge, not the 1 million device company. Somebody, not the company that actually has bought 1 million SIM-cards, determines whose IMSI is on the multi-IMSI SIM or gets send over the air to the eUICC. That is not what I envision, that is absolutely not what the 1 million device user wants. These companies want to be able to decide themselves, whether they use one, two or three mobile networks in a country. The 1 million device companies also want to determine if they can roam on Wifi using EAP-SIM or not. If the 1 million device company is not in charge, this is determined by others, whose businessmodel has different requirements.

What the Netherlands proposed is therefore that an energy company can obtain a single IMSI range and manage it in a way it sees fit. In a way that allows it to use Wifi, Dect-guardband and GSM/LTE as it sees fit.

Abhay Ghatpande

Aren’t multi-IMSI SIM cards already available for M2M?

Eli Lederwerg

I think it is excellent. And the way forward for the Internet of things and M2M.
Any company that is interested, we can make their SIM cards to their own specifications. Contact me :)


1. How would IMSI Swap possible over the air and ofcourse without operator intervention
2. Additionally regulator needs to be maintain open pool IMSI database in order to carry this transaction and moreover operator real time connectivity to provisioning systems/CRM needs to be managed in order to provision and de-provision the sim from respective network


IMSI swap very much happens ota with the same sim card, but with the operators support.. Unless it can be done over USSD. In this case the IMSI would migrate from the operator VLR (visiting) to the HLR (home) as the AUC would already have been registered on the home MSC (switch).


So this is only for Holland, right? What about the rest of the Netherlands? #pedant


my concern is that these SIMs would be embedded into the device. this actually gives the end user less flexibility tan a removable SIM which already allows for pretty easy carrier swapping with an unlocked phone. also the fact that is a physical SIM makes it very clear to the user what network they are utilizing.

i am against anything that takes control away from the customer and puts into the hand of the corporations whether carrier or phone manufacture.

also there are already MVNOs with their own SIM cards that roam between multiple carriers, especially in Europe.

Rudolf van der Berg

Frank, you misunderstand. These are for car companies, smart metres, ereaders, navigation, insurance monitors, where the customer manages 10k or even millions of devices. This is not for consumers


Yeah,w as thinking the same thing. Probably, more like Holland, Michigan to all Americans — yes I’m looking at you in Santiago de Chile… ;-[

Chandana Kulatunga

the network-less SIM is still illegal in almost every country in the world

This is because the goverments loose the way to track the user just in case. For better alternative is provide National ID number during the phone activation so the phone can pick up the packages we pre owned from the list and we pick the one we want


Network-less SIM is legal and exist since many many years. Its called Mobile Virtual Network Operator.

There are two flavours of it. One is having no infrastructure and is purely a marketing thing. The SIM’s are still from the donor network it has an agreement with. So this is more like a branding / marketing thing than anything else.

The second variant is having its own core infrastructure, own mobile network code, own HLR/MSC etc etc. And it has its own SIM cards and IMSI ranges. Technically speaking, tthe network is simply a network without the cell towers and the SIM cards are always roaming on some other network of choice. From a end user perspective, always being in roaming of course is considered “expensive” but this is just a question of the agreements between the MVNO and the visiting network and the pricing.

Micha Benoliel

Finally a regulator that understands how to unleash mobile connectivity. In addition this will boost innovation and open the road to additional and new revenue models.

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