There is something they say about digging yourself into a hole. It usually takes more time to claw your way back. That is, if you ever want to see light again.
The Nigerian Communications Commission, NCC, did not intentionally dig itself into a hole. Some people, given the responsibility to curate the day-to-day operations of the regulatory authority, dug the system into a hole. The Commission has been trying to fight its way back ever since, although it will take a longer time because of the absence of a board.
I was recently informed that the regulator will institute the Telecom Identity Risk Management Platform, TIRMP, by the last quarter of this year, to streamline the activities of churned numbers in the industry. That may not seem much but it’s one of the several actions the regulator is taking to fight its way out of the abyss. I am pretty sure that, at the end, people will be happy that such a step was ever taken. In the meantime, let’s do a little flashback to prove that, also in the last quarter of last year, the Commission executed some actions to demonstrate a seriousness that was more positive than pretentious. I will state just two.
One: Early last year, the regulator revised its telecommunications statistics to reflect Nigeria’s updated population estimates of 216,781,381, as projected by the Nigerian Population Commission, NPC, in 2022. The adjustment replaced the previously used 2017 population estimates of 190m.
There was only going to be one sure outcome. The teledensity dropped from 115.63 per cent to 102.30 per cent as the subscriber base also plummeted to 154.6m. It was a bold decision that jolted the industry into reality, an action that could hardly be contemplated previously when it was needed most.
Two: And this is connected to the foregoing. At the conclusion of the NIN-SIM regulation exercise, a much criticised programme, jointly executed by the NCC and the National Identity Management Commission, NIMC, the number of lines on the mobile networks dropped to 154m, with one operator losing as much as 40m lines. The announcement was made in October. It caused a lot of discomfort and business reimagining.
One would say that such an industry would have a lot of churned numbers. But it is much more than that. There are other reasons. At the dawn of the mobile industry, it was a thing of prestige for one subscriber to carry as many phones as the pouch can accommodate, those who wanted to enjoy the full expression of conspicuous consumption, although it was more of the limitations of the networks that were having a lot of headache in rolling out services after being jilted by a government that had promised so much.
The story has changed. Growth has plateaued and the economy has not been any kinder. For over a decade now, there are so many people slipping into multi-dimensional poverty for whom telephony means very little. For these people, it is a matter of the stomach first, the art of the mastery of survival in challenging times, while for the rest of us who had luxuriated in class, the economy has levelled everybody. Without seeking economic lessons, a number of subscribers have resorted to using one phone. So, there are more reasons for churn numbers in the industry; which is why it is salutary that the regulator has taken a decision to sanitise their use.
For more understanding of the churning process, the regulator explained that “when a phone number (MSISDN) has not carried out any Revenue Generating Event, RGE – outgoing or incoming calls or SMS, charged USSD sessions, data use, or any other activity on the line that generates income for the operator – for over 180 days, the MSISDN is deemed as inactive. If this inactivity continues for another 180 days, that is a total of 360 days, the line becomes eligible for churning, and recycling”.
Literally, the number has gone into a recycling bin where it can be retrieved by the operator and reassigned to a new subscriber, according to the QoS Regulation and Business Rules 2024.
But that’s just the beginning of a new journey as the dangers are embedded in the old number which could be harmful to the previous owner or be put to some unsavoury use by the new owner.
According to the regulator, the recycling of lines presents challenges, particularly when the previous owners of the reassigned numbers still have those numbers linked to services they used before the numbers were recycled. It presents issues of security and integrity of phone number ownership.
This is the reason the TIRMP is being put in place, to serve as some kind of clearing house for those numbers, help maintain their integrity and prevent innocent phone users from being harmed.
An NCC source gave further understanding. Any time a number is recycled, sensitive details of the previous user, like bank details, including balances, fintech details and even health, could still be in the number that can be manipulated by unscrupulous individuals. The Commission, according to the source, is therefore working with all the stakeholders, including the security agencies, the Central Bank, banks, fintechs and telecoms service providers, to ensure that every churned number will go to the platform which will automatically notify all the stakeholders. Is that what they call flagging?
The NCC is only acting within its regulatory powers to ensure that industry phone users are protected. For instance, in the UK, Ofcom, the communications regulator, is responsible for overseeing the recycling of mobile phone numbers.
In the UK, an MNO is allowed to deactivate an unused number, which is given a dormancy period of between 30 to 90 days, depending upon the carrier, before the number is reassigned. Although the operator is allowed to reset or erase data linked to the number, it is generally accepted that traces of its history can still be present, especially with online services that use SMS-based two-factor authentication.
Numbers are a limited resource which are strictly managed by the regulator and assigned to the operator. As it is in Nigeria, so it is in the UK where Ofcom ensures the reassignment of numbers by operators after the dormancy period due to the limited pool of available numbers.
But the Federation of Communications Services, FCS, of the UK has published procedures for mobile phone recycling that aims to discourage fraudulent activities and provide a clear defence against charges of handling of goods. A feature of such procedures is to ensure “that operators will place blocks on the records of devices for a wider variety of reasons.”
A clear point here, however, is to ensure that subscribers are preserved and that operators do the right thing by going through the platform which the regulator is putting in place. It portends a win-win for all stakeholders, including the subscribers.
“It will reduce fraud risks and improve our digital and financial services by enabling service providers to proactively detect and act, particularly to high-risk numbers, while updating customer KYC details where applicable,” the regulator said.
It is a good step in the right direction to checkmate the little demons that usually coalesce into giant forces to trouble the wider ecosystem. Much like the journey of a thousand miles beginning with one step. The challenge is to take the step at all, and that’s what the NCC has done.