Response to the Real-name Registration Programme for SIM Cards

Internet Society Hong Kong (ISOCHK) believes that the proposed Real-name Registration Programme for SIM Cards is damaging to Hong Kong’s reputation as a role model in the field of telecommunication policy. It will hinder the development of smart city, a commitment made by the Hong Kong Government, and deter technological innovation of the information technology industry. We oppose the proposed Programme and recommend a complete withdrawal of the Programme. 

A matter of principle

As the United Nations Human Rights Council’s Special Rapporteur on freedom of opinion and expression reports, “encryption and anonymity tools have become vital for journalists, activists, artists, academics and others to exercise their professions and their human rights freely”. [1] Individuals and organizations should have the right to hold and freely express opinions without interference and conduct their legitimate everyday activities under adequate privacy protection. ISOCHK believes that the proposed regulation will only undermine decades of efforts Hong Kong has made to protect and promote freedom of speech and to maintain a favourable business environment, jeopardizing Hong Kong’s role as an international finance centre.  

Proposal 1: SIM Real-name Registration Programme

ISOCHK does not support Proposal 1. The consultation paper depicts prepaid SIM cards (PPS) as a material factor in illegal activities. We do not believe it is true, and are of the opinion that PPS is a mere scapegoat. ISOCHK highlights the following:

According to the Secretary for Security Mr John Lee’s written reply to Hon Vincent Cheng in Legislative Council on 13 January 2021 [2], the majority of telephone deception cases originated from outside Hong Kong. We do not see how real-name registration of local SIM cards could address the problem and we can foresee the prevalence of similar phone scams even after the Registration Programme is put into effect. Without disclosing the ratio of telephone deception cases involving local SIM cards versus overseas callers, the claim made by the consultation paper is incomplete and misleading. 

The consultation paper also argues that serious and violent crimes threaten public safety, hinting at the possibility that criminals would make use of local PPS to conduct their activities. ISOCHK would like to point out that it is easy for any serious criminal to obtain overseas SIM cards; they may also look for scapegoats to bypass the real-name SIM card registration. Worse still, it is also foreseeable that identity theft or SIM swapping attacks would become a more apparent concern once the registration programme comes into effect, imposing additional risks to innocent individuals and businesses. 

If crime prevention is an important concern in the legislative exercise, ISOCHK regrets to comment that the proposed Programme will be gravely ineffective. The burden and restriction it places on service providers and consumers are utterly unnecessary and disproportionate vis-à-vis the purported purpose.

Hong Kong has been one of the safest cities in the world since the introduction of mobile telephone services back in the 1990s, and has always been a successful role model of a free city with low crime rate and high adoption of telecommunication technologies. The consultation paper’s accusations that the anonymous nature of PPS “undermines confidence in the integrity of telecommunication services” and “jeopardizes the genuine or legitimate use of telecommunication”, when scrutinized against the city’s experience, are utterly gratuitous and unsubstantiated.

Proposal 2: Three PPS cards restriction per user

ISOCHK does not support Proposal 2. It proposes to limit the number of SIM cards to three (3) per user, including company and corporate users. It is obvious that the authorities have not thoroughly considered reality, in this case, the increase of mobility devices per individual in the era of Internet of Things (IoT) and 5G. Based on the World Bank’s 2019 data [3], each person in Hong Kong subscribes to 2.89 mobile services on average. It is expected that this number would only increase in the coming years. The proposed restriction of three SIM cards per individual is no doubt unrealistic, disregarding the fact that many people use more than three PPS for their own devices for emergency internet access during network outages or have dual SIM cards in the same phone for extra mobile data quota.

The proposal does not detail any arrangement on SIM cards for machines, such as automobiles and shared bicycles, or fixed installation such as vending machines and advertising panels. Many of these devices require the use of SIM cards to perform remote management, security update, location tracking and content delivery. It is also common for the information technology industry to conduct research and test resiliency, compatibility and security of their products and services by using dozens or even hundreds of mobile devices simultaneously. The proposal illustrates not only the government’s ignorance and disregard of the IT industry’s real practices, causing inconvenience to the daily operation of hundreds of businesses, but also paints a very discouraging future for the industry, further accelerating the relocation of companies and emigration of talents since the establishment of the National Security Law. 

Proposal 3: Registration endorsement for young persons

ISOCHK does not support Proposal 3. We do not think the registration endorsement could provide any substantial protection to young people. Speculating on the assumption that criminals would lure teenagers to register SIM cards for illegal use, the consultation paper proposes that adolescents be required to seek endorsement from parents, relatives or guardians before obtaining registered SIM cards. On a practical level, this only imposes extra difficulties upon service providers to prove such relationships, and is not at all helpful in preventing identity theft, or barring teenagers from selling their SIM to criminals for profit. It would, however, put teenagers into a disadvantageous position in which, with increasingly extraordinary law enforcement and prosecution practices, youngsters lacking legal knowledge and experience would be dragged into criminal proceedings and even challenged to prove their (legally presumed) innocence in case of SIM card misuse. 

The registration would also bring obstacles to the promotion of STEM education to children. The added cost and endorsement procedure would discourage talented children from exploring and learning innovative technologies that involve the use of mobile networks. Children, especially those living in grassroots communities, might lose their opportunity to learn if access to mobile networks requires approval of adults who do not understand the importance of it. 

Proposal 8: Record requests from Law Enforcement without warrant

ISOCHK does not support Proposal 8. The proposed regulation grants power to law enforcement agencies (LEAs) to request registration information under “urgent or emergency situations”. Yet, the definition of “urgent or emergency situations” is unclear and the power itself lacks independent checks and balances. As the National Security Law has already granted LEAs the right to request service providers to provide assistance whenever deemed necessary, it is redundant and excessive for the proposed legislation to grant LEAs access to the records without warrant. 

In addition, there does not seem to be any clear mechanism to prevent abuse of such private information. It is foreseeable that the abusive power given to LEAs could easily be weaponized and become a tool to harass or threaten dissidents. As the UN opines, “when States legitimately need access to encrypted or anonymous information, they should only seek it through judicial process”. [1] ISOCHK only supports that LEAs may request licensees to provide SIM card registration records of relevant individuals and time ranges when a warrant is issued by a magistrate, where it is necessary for LEAs to conduct investigation and the magistrate is satisfied that all other less intrusive methods have been exhausted. 

Internet Society Hong Kong

25th February, 2021




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  1. 建議數量對需要進行開發及測試應用程式的前線員工極為不便、條文沒有清晰界定機器對機器 (M2M) 連接電話卡在實名制外, 官僚制度使中小企無所適從
  2. 實名制不能阻止利用境外電話假冒成本地電話的犯案、亦會增加不法份子透過偷竊及威嚇手段盜用市民電話卡的可能性,巿民或會因此成為代罪羔羊
  3. 建議沒有釐清迫切或緊急之定義,導致執法部門權力過大
  4. 聯合國人權高級專員辦事處一份2015年的報告已指出,言論自由需要有足夠的加密法及匿名權才有足夠的保障,報告建議世界各地應該盡可能避免實名制
  5. 實名制使電訊商收集及儲存更多個人資料,但香港現階段沒有足夠成熟的私隱政策保障市民的應有的權利


Internet Society Hong Kong (ISOC HK)
資訊科技界選委 黃浩華

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Internet Society Hong Kong Chapter



The Annual General Meeting (AGM) of Internet Society Hong Kong Limited will be held on 22-Dec-2020 (Tuesday).

The Election of the Board of Directors will be held in the AGM. Five seats of the Board will be opened for election, with four seats for the full member category and one seat for the general member category. For joining the election, please fill in the appropriate nomination form and submit the form on or before 15 Dec 2020.

Annual General Meeting 2020

Date: 22nd December 2020 (Tuesday)

Time: 7:30pm – 8:30pm (please be punctual)

Venue: Oursky, Room B, 10/F, Great Wall Building, Lai Chi Kok, Hong Kong  (You may also choose to attend online with our meeting room link)

Participants: Internet Society Hong Kong members only

Registration: Please email your name to [email protected] with subject “Registration for AGM 2020” 

Agenda of Meeting

  1. Confirmation of Agenda
  2. Confirmation of Minutes of Previous Meeting:
  3. Confirmation of Business Report
  4. Confirmation of Financial Report
  5. Election of Board of Directors
  6. AOB


The documents are password protected. Please reach out to [email protected] for password.

Financial report:

Nomination forms for Full Member:

Nomination forms for General Member:

Members can also participate through signing the proxy form:

Election Committee

An Election Committee was appointed on 27th November, 2020. The members are Jacky Ng, Wo Sang Yeung, Chester Soong and SC Leung.

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HONG KONG INTERNET GOVERNANCE FORUM (HKIGF) ROUNDTABLE: Is the National Security Law Hong Kong’s Great Firewall? 香港互聯網管治論壇: 網絡長城——港版國安法與網絡自由


Hong Kong Internet Governance Forum: Is the National Security Law Hong Kong’s Great Firewall?

  • Date: 18 NOV
  • Time: 7pm – 9pm 
  • Venue: ZOOM
  • Language: English

On July 1, Hong Kong’s sweeping new national security law came into effect. Though the law doesn’t target the technology sector per se, Article 9 stipulates that the Hong Kong government “shall employ necessary measures to strengthen publicity, guidance, oversight and management in schools, social organizations, media, networks and other matters related to national security,” with “networks” here referring to the internet.

Though it still seems unclear how the law may practically be carried out, we can already see such a chilling effect. Facebook, Google and Twitter suspended user info requests from the Hong Kong government, some VPN firms shut down Hong Kong servers, the mobile app ‘Eat With You’ which labels local eateries supportive of the Hong Kong protesters terminated its service. Not to mention some residents have started to delete their Twitter accounts and messages over security law concerns. 


※Antony Dapiran – Hong Kong-based writer and lawyer, author of the book ‘City on Fire: The Fight for Hong Kong’

※Ho Wa Wong – Founder of g0vhk

※Edwin Chu – Co-founder of Enyk Security

※Sharron Fast – Lecturer at the University of Hong Kong’s Journalism and Media Studies Centre (JMSC)

※Charles Mok – Legislative Councillor (Information Technology)

In this Webinar, we have invited experts from different aspects to talk about how the security will affect Hong Kong citizens’ online activities, as well as how it may affect tech entrepreneurs and larger companies as they go about their day-to-day operations and long-term plans. And how can the tech civil society deal with this situation. 

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[Webinar] Data for Environment: From Insight to Action

Prof. Rolien Hoyng, School of Journalism and Communication, CUHK and the Internet Society Hong Kong are organising Data for Environment: From Insight to Action. We invite you to join our webinar discussing the role of data in tackling the environmental problems that cities like Hong Kong are facing.

The event explores how better access to, and use of, data can contribute to social innovation and awareness of environmental threats such as pollution and waste. What kinds of data would be necessary and what can be done with them? What can Open Data mean for stakeholders such as environmental NGOs and how can they push for it? 

Date: 23 October, 2020 (Friday)

Time: 15:30 – 17:30

Venue: Online meeting room



  • Prof. Daisy Tam, Department of Humanities and Creative Writing, HKBU

Prof. Tam will talk about her research journey in food waste and her web application Breadline (by HKFoodWorks) which uses data to decentralise food rescue operations. 

  • Prof. Wilson Lu, Department of Real Estate and Construction, HKU

How much construction waste is being dumped illegally in Hong Kong’s countryside? Prof. Lu is going to tell us about his research project that dug out the truth using data mining and modelling. 

  • Mr. Wendell Chan, Project Officer of Friends of the Earth

How “green” are LegCo and District Councils? Friends of the Earth looks into the meeting minutes, attendance and voting record of council members to find out how committed they are to environmental issues. 

  • Dr. Scott Edmunds, CivicSight (formerly Open Data Hong Kong) & CitizenScience.Asia

There are not many publicly available academic and government data in Hong Kong. That was why Dr. Edmunds mobilised the power of citizen-collected data in his crowdsourced mosquito detection projects and in understanding other environmental issues.

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