Corporate SIM card registration: a new employer obligation

Due to the amendments to Law of 07.07.2003 N 126-FZ “On Communications”, companies that use corporate mobile communications have new obligations from 01.06.2021. These changes are introduced to limit telephone fraud.

Changes

Companies are obliged to enter information about corporate SIM card users into the Unified System of Identification and Authentication (hereinafter – “USIA“). The obligation also applies to SIM cards used in tablets, online cash registers, video surveillance systems and other equipment.

The amount of information submitted will differ, depending on whether you are submitting information about the numbers assigned to employees or those used in corporate technology.

Telecom operators are obliged to verify the availability of the confirmed information in the USIA and, if not, to restrict the provision of communication services to the numbers in question. Please note that the operators’ responsibility is to verify information. They are not obliged to submit the information for the company.

How to submit the information

Company can submit the information in two ways:

• The company submits the information about phone numbers itself using the Guide posted on the State Services portal (hereinafter – “GOSUSLUGI”). Then the employee receives notification to confirm the information. This is required to do, so that the service provider starts to provide their service. The deadline for the employee’s confirmation is set out below.

• The employee registers the number themselves using Activating corporate SIM card The exact name of the company and its INN are required, otherwise the SIM card will not be activated. Please note: the employee must be logged in to GOSUSLUGI before clicking the link.

Deadlines for submitting information

If the communications services contract is concluded before 01.06.2021, the information must be submitted at the latest:

• 01.03.2023 – for equipment users;
• 11.2021 – for corporate mobile users.

If a contract is concluded after 01.06.2021, the information must be submitted before the provision of communication services. Without this information, the operator will not authorise by sending a notification. If no information is provided, the number will be excluded from the contract.

Using GOSUSLUGI

Despite GOSUSLUGI popularization, not all companies and individuals are connected to it.

In particular, currently GOSUSLUGI does not provide for the technical possibility to register branches and representative offices of foreign legal entities due to their lack of Primary State Registration Number (OGRN).

Thus, foreign companies still do not have the opportunity to submit the information regarding the SIM cards used in the equipment due to the lack of a personal account there and alternative options for reporting the information. We have contacted the Ministry of Digital Development and received an official response that the functionality to register representative offices and branches of foreign companies is scheduled to be put into operation in September 2021, and companies will have the opportunity to submit data before the deadline.

We also recommend considering the option of using employees’ personal numbers for this purpose, with subsequent costs reimbursement. In doing so, you should analyze with the technical specialists what confidential information the employee can access and what risks may arise from such a decision.

Other companies must register on GOSUSLUGI, following the Guide.

Employees can submit the information on their corporate numbers themselves through via their GOSUSLUGI personal accounts.
Foreign nationals can also register on GOSUSLUGI if they have SNILS (personal insurance policy number). If a foreigner national does not have a SNILS, we can help with its obtaining, after which the foreign national will have to confirm the account created in USIA at the Multiservice center (MFC) providing a passport and SNILS.