Embedded SIMs: they're happening, and Apple thinks they could be in consumer products

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Rumors have long persisted that Apple has explored the use of embedded, non-removable SIM cards in the iPhone and iPad. From an OEM's perspective, it's easy to see the appeal: eliminating the user-accessible SIM card mechanism from a device reduces complexity, leaves more room for internal components, and likely makes the hardware more appealing to carriers who'd like more decisive means of ensuring lock-in. Though the European Telecommunications Standards Institute (ETSI) just approved the so-called nano-SIM format in the past few hours — the card designed to replace the micro-SIM and mini-SIM that phone users are accustomed to — the organization is already well on its way to setting the rules for eUICC: the Embedded Universal Integrated Circuit Card. In other words, an embedded SIM.

The impetus for the eUICC standard comes not from phones, or even consumer products at all, but from the M2M (machine-to-machine) industry — the millions of sensors, embedded computers, and other miscellaneous devices in vertical markets that benefit from cellular connectivity. In the words of the ETSI:

Work on Machine-to-Machine (M2M) applications has given rise to the possibility of having a UICC that is embedded in a communication device in such a way that the UICC is not easily accessible or replaceable. The ability to change network subscriptions on such devices becomes problematic, thus necessitating new methods for securely and remotely provisioning access credentials on these Embedded UICCs (eUICC) and managing subscription changes from one MNO to another.

Unlike the heated debate that's taken place over the exact size and shape of the nano-SIM, standards-setting on the eUICC has very little to do with physical design at all: it's little more than a chip inside the device and it doesn't need to be swappable. Instead, ETSI members are currently debating how embedded SIMs should be programmed and provisioned remotely. What if a device needs to be re-provisioned for a different carrier? What if a device is mounted in some remote location that isn't easily accessible? What if a device changes owners?

Though M2M is the focus with this standard, that's not to say ETSI isn't considering the possibility that consumer devices (read: phones) will use eUICC — there are entire sections of the draft requirements document devoted to consumer use, in fact. Here's a use case that the organization lays out for provisioning a new device, for instance (emphasis ours):

A consumer purchases a new device with an eUICC and then selects an MNO for communication services. The MNO might be selected at the same or another retailer, at an MNO shop or online and will be activated within a short period. First use of the new device will be with the first subscription already set-up, or if no subscription is set-up, the customer will select an MNO and, if required, after appropriate authorization a subscription will be set-up. Subscription set-up happens on either the mobile network using a provisioning profile or any other connectivity mechanism provided, subject to required end-to-end security being provided e.g. LAN, WLAN, Bluetooth, or USB.

The subscription management will be automated for this single consumer subscription between the consumer and the MNO. The consumer agrees to the contract with the MNO for the subscription for the communication services.

Provisioning via USB rings true to something Apple would do, of course: it already offers carrier unlocks in some circumstances via iTunes, and it's easy to imagine that it would like to be able to complete the entire provisioning process out of the box using a customer's computer without needing to ship different SKUs to different carriers loaded with different SIM cards.

Is this why Apple has fought anything but a mild refresh with nano-SIM?

Notably, a dust-up between RIM, Motorola, and Apple during nano-SIM discussion at the last ETSI meeting in March gave some insight into where the industry's head is at on the topic of eUICC: in support of its more radical nano-SIM proposal, Motorola noted that eUICC is currently geared at industrial devices which suggests that nano-SIM will be around long enough to justify a serious overhaul. Apple, though, "disagreed that there is any statement forbidding the use of an embedded UICC in a consumer product." That's telling.

Is this why Apple has fought anything but a mild refresh with nano-SIM? Does it assume that embedded SIMs are around the corner for consumer devices — phones included — and therefore putting any more work into nano-SIM than is absolutely necessary would be a waste of time?

eUICC is far from ratified, but we'll be following the story closely as it progresses.

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