Uganda: SIM card registration requirements must respect fundamental rights

As the seven day deadline for registration of all SIM cards set on 12 April by the Uganda Communications Commission (UCC) approaches today, ARTICLE 19 calls on the UCC to rescind the directive and safeguard the right to free expression, privacy and equal access to telecommunication services in Uganda.

The UCC’s directive is a further extension of previous attempts to make SIM card registration mandatory, and requires all Mobile Network Operators to register and verify all SIM cards in the country. After 20 April, any non-registered and non-verified SIM cards will be deactivated.

The directive comes at a time when many Ugandans still do not have national identity cards or passports, due to administrative challenges in processing national IDs since they were made mandatory in February 2014. Equally, Uganda is home to many documented and undocumented refugees and internally displaced persons (IDPs) who may not have access to national identity cards or passports.

“This directive could deny thousands of people in Uganda access to telecommunications services, and should be immediately rescinded. Freedom of expression and access to information, through the internet and other forms of telecommunication, is a fundamental right which must be guaranteed for all people regardless of their economic or other status, and should not be arbitrarily limited based on possession of identity documents”, said Henry Maina, Regional Director of ARTICLE 19 Eastern Africa.

In addition to violating free expression standards, the directive creates serious concerns for privacy and media freedom. The ability of journalists and citizens to remain anonymous while exercising their freedom of expression is important in ensuring individuals have the ability to freely enjoy their right to impart and receive information, free from State control.

Any requirements for mandatory SIM card registration unduly limit the individual’s right to privacy and anonymity in exercising free expression, as noted by the United Nations Special Rapporteur on Freedom of Expression in his June 2015 report on encryption and anonymity. Not only does this directive violate international standards on the mutually reinforcing rights of free expression and privacy, but an earlier 2013 report by the Special rapporteur has highlighted that SIM registration databases are vulnerable to identity theft, fraud and accidental disclosure”, added Maina.

Although Article 27(2) of Uganda’s Constitution provides that  “No person shall be subjected to interference with the privacy of that person’s home, correspondence, communication or other property”, administrative actions have not respected this principle. While the UCC is charged with regulating and licencing telecommunications under the Communications Act 2014, a comprehensive privacy law is required to ensure its directives comply with free expression standards. It is therefore essential that an amended Data Protection and Privacy Bill is passed.

ARTICLE 19 urges the Uganda Communications Commission to respect and uphold the right to freedom of expression and information as recognised in the Ugandan Constitution, as well as in international law.

We call upon the government to rescind the UCC directive on SIM Card registration, halt the deactivation of unregistered SIM cards and ensure all future directives fully comply with the right to freedom of expression, information and privacy. The Ugandan government should also seek to pass a revised Uganda Privacy and Data Protection Bill in line with international freedom of expression standards as recommended by ARTICLE 19 in its 2016 submission to the UCC.

For more information, please contact Henry Maina, Director of ARTICLE 19 Eastern Africa at or call on +254 727 862230

 For more on privacy and free expression, read our new Global Principles on Protection of Freedom of Expression and Privacy