Newsletter
Service Providers Engaged in the Wholesale and Resale of Subscriber Numbers to Register as Telecommunications Operators in order to Obtain Subscriber Numbers
On April 26, 2024, the National Communications Commission (NCC) announced the Regulations Governing the Use of the Subscriber Numbers on Telecommunications Operators (the "Regulations") on February 23, 2024 to extend the KYC and risk management obligations to service providers engaged in the wholesale resale of subscriber numbers, such as Mobile Virtual Network Operators (MVNOs) (the “Resellers”).
After the Telecommunications Management Act came into effect on July 1, 2020, certain Resellers (i.e., type-two telecommunications operators under the old Telecommunications Act (電信法)) were able to cancel their telecommunications operator’s registration. However, following the announcement of the Regulations, telecommunications operators that have been allocated subscriber numbers are required to conduct reviews if they provide such numbers to the Resellers. This includes checking whether the Resellers have registered as telecommunications operators, as well as verifying basic information such as the nature of their business, capital amount, and number of employees, as well as the intended use of the wholesale subscriber numbers. Due to these requirements, Resellers may need to register as telecommunications operators in order to obtain subscriber numbers.
In addition, both telecommunications operators that have been allocated subscriber numbers and the Resellers are required to fulfill KYC, risk management and internal control audit obligations. For example, before assigning a subscriber number to a customer, they must verify and register the customer's information or conduct an on-site visit to a corporate client.
The Regulations will impact those telecommunications operators that have been allocated subscriber numbers and the Resellers, particularly as some Resellers may need to register as telecommunications operators. It is advisable for related businesses to assess in advance whether they are compliant with the Regulations. If you have any questions, please contact our Digital Industry, Communications and Personal Data Protection team.