What the NTC ordered
The Daily Tribune reported on 28 October 2026 that the National Telecommunications Commission (NTC) will give telecom operators 15 days to verify subscribers holding more than 100 mobile numbers under a single name. Numbers that fail the check are to be deactivated. According to the report, the directive was issued on a Tuesday, and the 15-day clock begins on receipt of the memorandum order. The stated targets are organized scam operations, fraudulent financial transactions and illegal SMS blasting. Operators must run stricter know-your-client checks to establish whether subscribers still possess and control every SIM registered in their names.
A caveat on sourcing: we could not retrieve the NTC memorandum itself, so the details below rest on press reporting. The order number and exact text should be checked against the primary document.
The strongest case for the order
The regulator's logic is easy to state. A person who holds 100 or more SIMs is rarely a heavy personal user. Large pools of registered numbers are the raw material of scam infrastructure: bulk SMS phishing, mule accounts and SIM-box or SMS-blaster operations. The SIM Registration Act (Republic Act No. 11934, approved 10 October 2022) was meant to make mobile numbers traceable to real people. It has little value if one registrant, or one stolen identity, can anchor an unlimited number of lines. The Tribune notes that the Act does not limit how many SIMs an individual may register. A threshold check is a way to close that gap without amending the statute.
The Act also already criminalizes the conduct at issue. Section 11 sets penalties for registering with false information or a fictitious identity, for spoofing a registered SIM, and for selling or transferring a registered SIM without complying with registration. For selling or transferring a SIM without complying with registration, the penalty is imprisonment of six months to six years, a fine of P100,000 to P300,000, or both. So the NTC is not inventing a new offense. It is trying to find existing ones.
Where the design is sound
Three features make this a better instrument than most SIM crackdowns.
- A high threshold. One hundred SIMs sits far above any ordinary household, small business or family plan. The check concentrates on the extreme tail rather than sweeping up typical users.
- A test of control, not identity alone. Asking whether the registrant still holds and controls each SIM goes after the actual failure mode: numbers registered by one person but operated by someone else.
- A route back. NTC Deputy Commissioner Alvin Blanco was quoted as saying deactivation is permanent unless the person can prove, with proper identification documents, that the affected SIM is registered personally under their name. That is at least a recourse.
Where proportionality needs work
The weaknesses are procedural, and they are the kind that determine whether an enforcement tool is trusted or abused.
First, the reported remedy is thin. Permanent deactivation, with proof by ID, is a heavy sanction for a number that may be tied to a bank account, a business line or a two-factor login. Legitimate bulk holders exist: IoT deployments, customer-service operators, logistics firms, bulk-messaging vendors. If they are caught, the burden is on them to prove a negative within a window set by the operator's compliance cycle, not by an independent decision-maker. A short notice period, a defined appeal path and a clear distinction between suspension and permanent deactivation would cost the NTC little and would reduce wrongful loss.
Second, the check puts private operators in the role of adjudicators. A telco judging whether a customer uses a SIM "legitimately" has commercial reasons to over-deactivate rather than risk regulatory penalties. Published criteria, so that operators and subscribers know what counts as proof of control, are the standard remedy.
Third, data handling. Section 9 of RA 11934 makes registration data absolutely confidential, with exceptions for a court order on probable cause, a subpoena-based process under Section 10 and the subscriber's written consent. The statute requires retention of data for ten years after deactivation. A sweep that makes operators re-collect and re-verify identity documents from the most heavily flagged subscribers expands the data-handling surface. It should be run under the Data Privacy Act of 2012 (RA 10173), whose Section 11 requires transparency, legitimate purpose and proportionality, and requires that data be adequate and not excessive for the purpose. The National Privacy Commission, created by Section 7 of that Act, is the natural body to review whatever documents operators are asked to collect. We could not confirm any NPC guidance on this specific order.
The broader lesson on identity-linked telecoms
SIM registration is a trade: telecom traceability in exchange for pseudonymity. Civil liberties groups have long argued that anonymity protects people who face real risk from being linked to their speech. As the Electronic Frontier Foundation puts it, many people "don't want the things they say online to be connected with their offline identities." A mandatory identity layer on mobile numbers is justifiable only when its enforcement stays narrow, evidence-led and reviewable. Aiming at a 100-SIM outlier is consistent with that. Extending the same logic to a low cap, such as the 10-SIM limit that the order's press coverage says the Department of Information and Communications Technology previously floated, would be a different matter. We could not verify that proposal and do not treat it as law.
What to watch
- The published order. Does the memorandum define "legitimate use" and specify how operators must document each decision?
- Appeal and reinstatement. Is there an independent review, and what is the timeline?
- Outcome data. The NTC should report how many SIMs were checked, deactivated and later restored, and whether scam volumes fell. Without that, the program cannot be judged on evidence.
- Mission creep. Any move from a 100-SIM outlier check to lower thresholds should require a statutory basis and a public consultation.
The NTC has picked a defensible target. The test of the policy is whether the person on the wrong side of a false positive has a fast, fair way out.