Implications of multi-SIM users for mobile money services

I a recent article published by CGAP (Read here), the phenomena of multiple SIM cards for one user is discussed. In this article, Jan Chipchase talks about the fact that subscribers often own (and use), more than one SIM card from different operators. Often the subscriber cannot afford two phones (or does not want to carry two phones around). The result is that unique mechanisms and behaviour can be identified in these markets. The most obvious being a market for phones that will accept more than one SIM card.

Jan makes an important point that may seem obvious: identity of a cellphone user is tied to a SIM card and not a phone. Two SIM cards mean two identities. In the world of transformational banking, this does mean two wallets. It is therefor extremely likely that consumers would own more than one wallet in a world of multi-SIM. This poses interesting questions:

• How does this impact on regulatory requirements? In most of the regulatory dispensations, subscribers are subject to limits (value in a wallet, daily transactions etc.). Should a system cater for this and recognise that a subscriber actually have two or more wallets?
• How should one deploy the user interface in a multi-SIM phone? How would a transaction look like (or work) where a payment is made from one SIM card to another in the same phone?
• Thinking a bit into the future, where the secure element for an NFC transaction is suppose to reside on the SIM card, how would this work if the phone has two SIM cards?

This just again show how important it is to develop mobile financial strategies around the SIM card in emerging markets. This concept is quite foreign in a smart-phone world, where the identity dependency of the SIM card is not always visible (or masked).