A ban on the issuing of new SIM cards and processing of SIM swaps in Uganda remains enforced, although the country's communications regulator has now introduced steps to be followed in exceptional circumstances.

In a message to telcos, Godfrey Mutabazi, Executive Director at the Uganda Communications Commission (UCC), said "As the Commission concluded the process of implementation of the API with NIRA to ensure verification and validation of SIM card registration information, please be advised that SIM cards can only be swapped or replaced under the following conditions. (At the) production of a valid police report, presentation of a letter from NIRA verifying and validating that a SIM card holder's National Identity Card is authentic, reregistration of the applicant for a SIM card by the telecommunications operator using biometrics and a photograph, issuance of a fresh SIM card registration from, and ensuring that the SIM card holder shall be using the SIM card in a genuine Type Approved device. The telecommunications operators are advised that SIM cards can only be swapped upon fulfilment of the conditions herein."

The temporary process from UCC has been criticised by members of the public.

Norbert Mao, a lawyer and President of the Democratic Party has described the new procedures as "superfluous". "Why should you have an ID and also have to produce a letter from the issuing authority confirming that the ID is not forged? Next will be to verify passports. A person who can forge an ID can surely forge an authentication letter from NIRA."

Ugandan media personality Denzel Mwiyeretsi believes the new procedures mean that it is easier to get a visa than to register a new SIM card in the country.

Dr Alison Gillwald, Executive Director at Research ICT Africa believes the SIM card registration drive in Uganda, first initiated in 2013, has some merit - although there are serious cost implications.

"Requirements for SIM card registration are popular in countries genuinely facing terrorists and high crime levels, and authoritarian regimes wishing to survey and control population, but there are several jurisdictions (democracies) where is has been publicly considered and not applied. It can be costly for operators at times when putting pressure on them to reduce costs, but there should be more concern about the poor who are most likely to not meet registration requirements."

Dobek Pater, Managing Director at Africa Analysis agrees that additional financial expenditure in the form of administration costs can be expected for a regulator and operators as the system for capturing the SIM card data is established, but adds that the process is also an opportunity for the operator to make money.

"SIM cards which are not registered but also do not generate revenue are 'cleaned out', providing an operator with recycled numbers which can be reused, thus saving the operator some money by not having to pay for new number licences on the Home Location Register i.e., it provides an operator with an opportunity to clean out its system of SIMs that were sold but are no longer active."

The UCC has not indicated when it expects the API to be completed.