The National Telecommunications Commission (NTC) has finally released the Implementing Rules and Regulation (IRR) of the SIM Card Registration Act, making it all set for nationwide implementation on Dec. 27. We took a careful look at the IRR, and we found one gaping loophole that may happen with the SIM Card Registration Law IRR.

The escape clause can be found in the identification requirement and it is easy to understand why. The IRR states that:

For individual end-user, ANY of the following identification cards or documents photo shall be presented:

(i) Passport;

(ii) Philippine Identification System ID, or the Philippine Identification Card; 

(iii) Social Security Service ID;

(iv) Government Service Insurance System e-Card;

(v) Driver’s License;

(vi) National Bureau of Investigation clearance;

(vii) Police clearance;

(viii) Firearms’ License to Own and Possess ID; 

(ix) Professional Regulation Commission ID;

(x) Integrated Bar of the Philippines ID; 

(xi) Overseas Workers Welfare Administration ID;

(xii) Bureau of Internal Revenue ID;

(xi) Voter’s ID;

(xiv) Senior Citizen’s card;

(x) Unified Multi-purpose Identification Card;

(xvi) Persons with Disabilities card; or 

(xvii) Other valid government-issued identification with photo.

Interestingly, the last one on the list is a catch-all phrase that says “other valid government-issued identification with photo.”

As such, Barangay IDs as well as Barangay Residency Certificates shall be valid since they meet the simple requirement: government-issued identification with a photo. 

The problem is that we know how easy it is to get them and even to fabricate or fake them, unlike the other enumerated IDs that are issued by government agencies at the national level. Barangay officials, as they are known, are very lenient. In addition, the IDs and certificates they produce are often cheap and easy to reproduce. See examples below:

Moreover, since the entire SIM registration process will be accomplished electronically or online as mandated by the IRR, there is no harm in trying to use fake identifications. There is little to no chance of getting caught given that registration doesn’t require a physical appearance.

Having said all that, it seems that faking one’s identity under the SIM Registration Law is not a big task at all. Unfortunately, we can’t blame the legislators for allowing such a permissive identification. This is because not every individual end-user holds any of the 16 government-issued IDs and restricting them to register is another legal issue.

featured image courtesy of Mikhail Artamonov