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Deadlines And ultimatums: What NCC SIM/NIN linkage deadline means for Nigeria’s informal economy

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In December 2020, the Nigerian Communications Commission (NCC) instructed mobile network service providers to deactivate, within a 2 week period, SIM cards that were not linked to National Identity Numbers (NIN). Expectedly, this decision was met with uproar from citizens because the announcement was made during the Christmas season and was asking for what was clearly an impossible feat.

Two months later, the deadline has been shifted at least twice, with 6 April 2021 set as the new deadline. Amidst all the panic and public backlash, one major question remains key, “Can the government cash the huge cheque it has just written?”

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An unachievable feat marred by
infrastructural deficits

Let’s put this in perspective– it took 8 years to register about 42 million people on the NIN database. Considering that Nigeria has about 100 million mobile network subscribers, the National Identity Management Commission (NIMC) would need to register over 57 million subscribers within a 4-month window to meet this target. Granted that as many people have more than one SIM; the actual number of new registrations could be fewer. Nevertheless, many of the 57 million unregistered active SIM card owners will be largely in underserved, rural and urban poor areas without the requisite access to the systems to enable registration. These people are also the ones who will be most impacted negatively, by being disconnected from network services after the deadline set by NCC has lapsed. NIMC says that they have instituted an online pre-booking system that only allows pre-booked persons to attend their offices for registration on any particular day and they have encouraged pre-enrollment via their portal. This move is definitely laudable, however, it does not take into consideration how many people have access to internet connectivity or internet-enabled devices. This delivers an interesting Catch 22: the people who are able to take advantage of these online registration platforms are likely to be the people who are already registered or can be registered with ease and therefore do not need assistance or support in facilitating the process. If the costs and barriers associated with the identity registration process appear to outweigh the benefits of actually having a registered identity, how will success be achieved?

The Federal Government recently approved the extension of the tenure of NIN enrolment agent licenses for Mobile Network Operators (MNOs) by five years; a good step that incentivizes MNOs to apply their considerable infrastructure to remove some of the existing bottlenecks and achieve the scale required in what is a very intensive process. Irrespective, meeting the 6 April deadline is still highly unlikely due to constraints in requisite infrastructure resources like manpower, stable electricity, and internet connectivity as well as the technology that registration centres need to register those without a NIN. In fact, it is these same challenges that motivated the request of almost half a billion dollars in loans from the World Bank to facilitate the increase of registration centres necessary for NIN registrations.

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And yet, the deadline imposed by the government will have us believe that it is trying to encourage citizen compliance for a process with challenges that are more related to a fundamental lack of harmonisation, scale, capacity, and infrastructure than they are to citizen compliance. Threats of SIM disconnection instead of comprehensively addressing the infrastructural gap are likely to compromise public trust in the system and could lead to general apathy when the necessary infrastructure is eventually in place.

NIN and the legacy of inequality
The existing inequality across the country will amplify the impact of this decision. When the initial two-week deadline was given, my eighty-five-year-old aunt, who can barely walk and spends most of her days making phone calls to her children across the world, panicked and was willing to go into a NIN office for registration, despite the risk due to COVID and her restricted mobility. For her, the possibility of having her two phone lines blocked would not only mean isolation from her family but also reflected the lack of inclusionary approaches when thinking about strategies to enable compliance. Beyond the elderly, Nigeria, like much of Africa, has seen a boom in mobile phone penetration and has come to rely on it in everyday life. An example is a driver or the roadside vegetable stall operator in Lagos, whose wife and children live in a rural area in Nigeria, and rely on their remittances and regular phone calls for survival and maintaining social networks. For them, the impact of disconnection will be most severe.

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Mobile phones are a business tool and income generator at the heart of Nigeria’s informal economy, with at least 71 per cent of Nigerians using mobile phones as their primary form of communication and about 10-20 per cent of them as a tool for internet access. The ubiquity of mobile phone use across the country has been instrumental in reducing the digital divide. The economic impact of a mass SIM card disconnection is likely to cripple the informal economy and further regress much of the progress made in deepening financial inclusion in Nigeria. For many businesses operating outside the formal economy, mobile phones boost efficiency, productivity, and income. Take hairdressers, for example, many of them are mobile and are able to provide home services to different customers whose sole means of contacting them is via their mobile phones. The same is true for plumbers, electricians, and tailors and many other professions within our informal economy. The assertion that millions of informal workers will be affected by this is far from an exaggeration and the ripple effects will amplify several socio-economic challenges which were already exacerbated by the COVID-19 pandemic. According to the Government Enterprise and Empowerment Programme (GEEP) COVID-19 impact survey, 91 of people have seen their incomes reduced as a result of the COVID-19 pandemic.

The question of data protection
Nigeria certainly needs a robust database supported by a proper foundational identity system that will benefit everyone–particularly micro businesses in the informal economy. However, with all this data being collected by the Federal Government across different platforms, there is an increased need to inquire about the safety of our personal information. In the twenty-first century, your personal data is your most valuable asset and the Facebook-Cambridge Analytica scandal of 2018 put to the forefront the idea that, while data collection may seem insignificant and small, it is an infringement on our rights to privacy and data security to have our data mined and commercialised without our consent. In Nigeria, data privacy is not as well entrenched as it should be. This example of a data breach is a microcosm of the kind of issues Nigerians may have to deal with–on a larger scale if the government does not properly ensure data privacy in the implementation of this new identification requirement and process, or millions of Nigerians are likely to be exploited due to the absence of coherent and constructive implementation of the current National Data Protection Regulation.

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Inclusivity – a fundamental step in policy design and implementation
Two things can be true. One, Nigeria needs a proper foundational identification system and the NIN is it. Two, this mandate put in place by the government–though well-intentioned– runs the risk of sabotaging itself. To avoid losing the heart of what it has set out to achieve, the government must focus on doing the work- ramping up infrastructure and SIMplifying the registration process – and creating a clear road map that ensures an inclusive process that will not exclude the vulnerable people already on the periphery of society. Nigeria cannot afford to alienate those at the bottom of the pyramid, who contribute substantially to the country’s development potential.

There is a disparity in realities that are telling of other inequalities in accessing basic services- and we cannot allow these disparities to determine who gets identified and who does not. Ensuring widespread financial inclusion and increased access to social and financial services, is itself reliant on the development and implementation of inclusive policies.

Debisi Araba is of the African Green Revolution Forum

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