Friday, November 7, 2014

Translation and explanation of revised Japanese SIM lock guidelines

Edit: I forgot to mention the best part. Not only will it be free, it will also be automated, meaning no more painful, time consuming experiences dealing with untrained shop staff. And, that of course means you will be provided with the unlock code.

I've now read the updated SIM unlocking guidelines from the Ministry of Infrastructure and Communications (MIC). I've also translated them below.

In short, I'm very pleased with the new guidelines. They are short, concise, specific, and (most importantly) thorough. I was worried that the MIC would focus narrowly just on SIM locks, leaving carriers free to cripple phones by a myriad of other means, such as locking out the APN settings menu on the phone (like Apple typically does).

The guidelines specifically state that any other restrictions added by carriers should be removed. Hopefully this means the end of the Docomo's automatically changing of APN when tethering, which breaks tethering with MVNOs, other SIM cards, and the ISP.

The guidelines also specifically state that carriers can no longer unlock a phone then refuse to provide service using non sequiturs like "because your phone is unlocked we are no longer able to service it." That is as logical as saying the train was a minute late because I put ham in the refrigerator.

Carriers will also be required to specifically disclose which frequency bands a phone supports,  as well as what services will cease to work. Currently, getting this information from docomo is tedious and uncertain.

Phones will still be sold in a locked state, and the guidelines allows for an a short period of time that the phone cannot be unlocked.

It would seem that Juggly was right (as usual). There is no room at all that I can see for carriers to take an opposite approach and cripple unlocked phones.

The guidelines do not go in effect until May 2015. Though there is a clause stating that these guidelines should apply to phones announced before that date, I do not at all expect that to happen. In that sentence, there was a line break that caused me to read over a very important character, 前. The old guidelines will apply to existing phones. Purchase phones that initially go on sale after May 5.

(なお、それ以前に発売された端末については、平成 26 年●月改正 前のガイドラインの趣旨に沿って適切に対応することが適当である。)

For the iPhone, this would mean the next iteration that would presumably become available around October/November 2015.

(Anything in [brackets] is added by me.)

May 2010 (Revised: 2014)


Currently in Japan, handsets provided by MNOs are "SIM Locked," preventing usage on other mobile networks.

Users of these devices have expressed the desire to both use their domestic devices while overseas with locally-obtained SIM cards and to continue using the same phone after porting their number to a different MNO.

Due to problems arising from large differences in specifications [i.e., WCDMA v CDMA-2000], frequencies, and platforms [i.e., carrier mail, etc.], individual MNOs were requested to voluntary abide by the "Guidelines Concerning SIM Locks" in 2010.

However, unlocking by MNOs remains limited at present. In addition, SIM locks have not only hindered users, but have also increased the cost to other MNOs of acquiring new customers, partially leading to the [unreasonably] large cash back offers.

Now, the spread of LTE and smartphones has changed the mobile marketplace, increasing interoperability of specifications and frequencies between MNOs. Therefore, both the basic and specific points of these guidelines should be adjusted accordingly.

Note: The guidelines defined 役務 (service) as electronic communication services concerning mobile phones, including mobile phone access service, 3.9G [LTE] access service, and virtual mobile electronic communication services associated with mobile phones.

Ministry Opinion

Article 29, Paragraph 1, Item 12 of the Telecommunications Business Act of 1984 allows for the invoking of measures to reform telecommunication practices that are unreasonable or unjust and may or do result in unsound industry development or are not in the best interest of the populace.

SIM locks constitute an inconvenience that prevents receiving service with existing handsets upon switching MNOs, as well as usage of a locally-obtained SIM card while overseas. SIM Locks further increase the cost incurred by MNOs in recruiting new customers and are the cause of differentiation in service fees and content [between new and existing customers], hindering competition. SIM locks are also the root of the large cash back offers used to acquire new customers that are promoting an unfair situation between longterm users and those who frequently change MNO.

However, MNOs have expressed the following concerns regarding not implementing SIM locking. 1) Lack of full support by other MNOs for unlocked handsets may cause confusion for users. 2) Compared to a market with locked handsets, promotional costs will increase, likely resulting in retail prices above current. 3) Loss of incentive to develop original brands and services.

Regarding 1), it is appropriate to leave the decision to users after sufficient explanation. Regarding 2), it is not likely to cause a large problem considering the typical user situation in which an amount equivalent to the handset cost is discounted monthly from the service cost. Furthermore, the cash back amounts at the time of purchase have become excessive, creating an unfair situation between longterm customers and frequent switchers and becoming a problem for fair competition. The removal of SIM locks is expected to result in restraint regarding these promotions. Regarding strategies for original branding (3), rather than using SIM locks to forcibly retain customers, it is preferable to develop and provide services that take maximum advantage of a handset's appeal.

Thus, the above concerns do not constitute proper and reasonable grounds to continue SIM locking. Finally, the traditional problem for unlocking (incompatible frequencies, standards, and specifications) continues to be lesser and lesser of a problem.

Considering the above, MNO's users (including those who have already cancelled service) have called for unlocking handsets, and in the lack of valid justification to the contrary from MNOs, it is necessary to invoke measures to reform current practices under Article 29, Paragraph 1, Item 12 of the Telecommunications Business Act to protect the interest of users and foster sound industry development.

Specifics for SIM unlocking

  1. Eligible handsets
    1. Carriers should in principle remove SIM locks from all handsets.
    2. Refusal to remove SIM locks is limited to cases that would result in unfair competition or excessive hinderance to usage with other carriers. (This applies to specialized devices that pose technical issues, i.e., nonstandard mobile specifications or frequencies and does not include general usage devices such as those commonly known as feature phones, smartphones, tablets, mobile routers, and USB modems)
  2. Unlocking process
    1. Carriers should whenever possible quickly and simply conduct unlocking through the internet or over the phone at no additional cost. (Alternate means for unlocking at no cost does not preclude the levying of a service charge if in-store unlocking is performed at the customer's request. A service charge may also be levied against customers with no active service contract for in-store unlocking.)
    2. Carriers may make exceptions and add a limited no-unlock period to prevent improper use of unlocked phone and mitigate the risk of loss of subsidized phones
  3. Unlocking process should be set in advance and publicly disclosed

Points to note during SIM unlocking

  1. Explanation to Users
    At the time of handset sale, SIM unlocking, or conclusion of a service contract, MNOs should make reasonable effort through means such as in-store explanation, pamphlets, or websites to ensure that the user understand the following points in particular.
    1. At time of purchase
      1. Whether the handset is eligible for unlocking
      2. The conditions and process of unlocking
      3. Which mobile services, applications, etc. will be partially or fully inoperable with another MNO SIM card
      4. The frequency bands supported by the handset
    2. At time of unlocking
      1. The conditions and process of unlocking
      2. Which mobile services, applications, etc. will be partially or fully inoperable with another MNO SIM card
      3. How to obtain service or repair for the unlocked handset
    3. At time of contract conclusion
      Which mobile services, applications, etc. will be partially or fully inoperable with another MNO SIM card
  2. Clarification of means for inquiry by users of unlocked handsets
    MNOs should consult with handset makers to prepare and clarify a means to perform service on unlocked handsets.
  3. Confirmation of proper technical certification
    MNOs should make efforts to confirm that uncertified phones are not used on their network.


Because it is desirable that unlocked handsets are as fully functional as possible, appropriate effort should be made to remove together with the SIM lock any additional restrictions on functionality that were set by the MNO.

Implementation of these guidelines

  1. These guidelines will be applied to new devices brought to market after May 5, 2015. It is further appropriate to suitably apply the pre-2014 guidelines to previously announced handsets.
  2. The Ministry of Internal Affairs and Communications will reevaluate these guidelines as necessary following based on the situation following implementation.


  1. What does this mean?

    > It is further appropriate to suitably apply the revised 2014 guidelines to previously announced handsets.

  2. That's a mistranslation. I missed the 前 because it was on a line break, so I read this: なお、それ以前に発売された端末については、平成 26 年●月改正 前のガイドラインの趣旨に沿って適切に対応することが適当である。

    As this: なお、それ以前に発売された端末については、平成 26 年●月改正 のガイドラインの趣旨に沿って適切に対応することが適当である。

  3. Thanks a lot for the translation.
    The guideline sounds very promising. I am looking forward to seeing more competition between the carriers and wonder how they will change their pricing model and compete for new customers. Subsidized handsets might more or less disappear, but being able to move freely from carrier to carrier without having to change the handset and sign a lock-in contract is certainly a big step forward. Farewell to lifetime-locked phones.

  4. So in short, they won't be unlocking phones bought before May 2015. Correct?

  5. I know. I'm really excited for this. The reason I held off on buying the models(iPhone user) this year was because I am not sure whether phones bought before the law took into effect are subject to unlocking as well.

  6. The guidelines won't apply to any phone that goes on sale before that date. So you if you bought an iPhone 6 in June, 2015, it will be forever locked.

  7. I bought an unlocked phone and I want to know if it can be used i have a AU line. i just switch the nano sim?thank yo

  8. Hi! Thaks for this post. Just wanna ask something.. Does this mean that Softbank will unlocked an iPhone that was bought before May 2015? I have an iPhone from Japan, curently, I live here in the Philippines, I can't use the iPhone from softbank, I've asked Softbank's customer support about if they are unlocking the iPhone that was already off-contract, but they didn't answer (I've tweeted @SBCare).

  9. According to the article, the carriers will not be required to unlock any phone purchased before May 2015. Which means your Softbank iPhone will almost certainly remain locked.

  10. Ohh.. That's sad. Anyways, thank you!

  11. BTW speaking of limiting functionality, one of the point upgrades to iOS 8 fixed the tethering APN override for MVNOs on docomo. I can now tether just fine on an iPhone 5s with a BIGLOBE MVNO SIM.