In Russia, they propose to legalize embedded SIM cards

Virtual operators GigSky and Truphone have been working in Russia for a long time, from which you can buy virtual SIM cards via the Internet

The Ministry of Communications is developing the necessary regulatory framework for the implementation of eSim (Embedded Sim) technology, that is, SIM cards integrated into mobile devices. In his commentary to Vedomosti, the information was confirmed by Deputy Minister of Digital Development, Communications and Mass Communications Oleg Ivanov. It is planned that the regulatory framework will be ready by the end of the year.

Embedded SIM cards are a very convenient technology, because you can connect to a telecom operator without visiting the operator’s office and receiving a physical SIM card. It is enough to scan the QR-code provided by the operator or download the operator's application - and the new number will be written into the built-in SIM card. For example, in iPhone Xs, Xs Max and Xr, you can save up to five carrier profiles in this way. It turns out that the phone can work in the networks of five operators: but this is only theoretically, because few operators support the technology.

Built-in SIM cards are supported in the latest iPhone, Google Nexus, tablets, Samsung and Apple smart watches. In the world about 30 operators support this technology. Last year, T-Mobile affiliates in Germany, the Czech Republic and Austria, the British EE, and Vodafone in Germany declared their support. In the US, eSim is supported by T-Mobile, Verizon and AT & T.
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Support for eSim is able to give impetus to the development of cellular communications and the Internet of Things in Russia, some experts believe, because in recent years the number of SIM cards sold has been steadily decreasing. According to AC & M-Consulting, this number has been decreasing for at least three years in a row.

The number of SIM cards sold in Russia

Year	Sold cards (million)
2015	128
2016	117
2017	110
2018 (forecast)	100

In addition, the familiar cellular communications market will change a lot, because they will not need intermediary dealers trading in operator contracts. Virtual operators can get a significant boost. In fact, in such a technology, while maintaining their permanent telephone number, subscribers will only choose between the mobile applications of different telecom operators, with the ability to quickly switch from one to another. At the end of 2018, virtual operators in Russia served 7 million subscribers (operators GigSky and Truphone ).

Interestingly, in such a situation, the mobile device manufacturer itself - Apple, Samsung or Google - or the developer of the operating system can become a virtual operator. For example, if the profiles of several real operators are recorded on the built-in SIM card, this virtual operator can optimize by choosing the network that is most beneficial for calling or using the Internet at the moment. It is possible that the user himself will be able to configure such profiles: the rules under which conditions which operator to use for traffic and voice calls.

In the information note, the Ministry of Communications and Mass Media notes that the use of such SIM cards does not require amendments to the legislation. This is the same identification module as a regular SIM card, and it can work in Russian cellular networks if there is a declaration of the device’s compliance with the Russian requirements for using communications equipment issued by Rossvyaz.

There are no legal obstacles to the introduction of eSim in Russia, but there are regulatory ones. Some regulation is needed. For example, the government-approved telephone service rules prescribe when a subscriber transfers a number from an operator to an operator, change the SIM card. Obviously, in the case of a built-in SIM card, this cannot be done, since it is not physically removed from the device. Therefore, the number portability procedure for eSim is not resolved. In other regulatory acts there are several more such inconsistencies that need to be identified and corrected.

The Ministry of Communications and Mass Media also notes the “lack of necessary infrastructure” among operators, but this does not seem to be a particular obstacle. Apparently, in this case, infrastructure means not so much physical equipment, but software systems for fast generation and support of virtual SIM cards, as well as for a quick procedure for transferring numbers from one operator to another (ideally, this should occur within a few seconds ).

Most likely, the regulation of the Ministry of Communications and Mass Media provides for a certain standardization of eSim, since operators' requirements for SIM cards and network settings are different. In addition, it is necessary to ensure fair competition measures so that device manufacturers do not preset the profiles of specific operators. Under the conditions of brand dominance, some operator may gain a dominant position in the market.