Retail SIM Sales Code of Conduct for Distributors

The Telecommunication Regulator of Cambodia issued a code of conduct in 2024 addressing the retail distribution of SIM cards, in response to persistent concerns about the way SIMs are marketed, sold, activated and, in some cases, re-sold in the informal market. The code applies to mobile network operators, their authorised distributors and retail agents, and to any party involved in the sale or activation of SIM cards to end users in Cambodia.

The measure follows earlier steps to strengthen SIM registration, to combat SIM-related fraud and to protect subscribers from misleading marketing at the point of sale. It is intended to raise professional standards across the retail channel and to clarify the responsibilities of each party in the distribution chain.

The code applies to any retail location or channel through which a SIM is sold to an end user, including operator-owned stores, franchised outlets, mobile money agents, general retailers, kiosks and, where relevant, online channels. It applies both to new subscriptions and to the sale of replacement SIMs to existing subscribers, and to prepaid and postpaid propositions alike.

The code operates alongside existing SIM registration rules, consumer-protection legislation and anti-money-laundering requirements applicable to bundled financial services. It does not replace these rules but articulates a common set of behavioural expectations for the retail channel.

At the point of sale, retailers are expected to provide clear and accurate information about the tariffs, allowances, validity periods, coverage limitations and any promotional conditions attached to the plan being offered. Retailers should not mis-describe services, should avoid pressure sales tactics and should ensure that customers understand any auto-renewal or default subscription features. Terms and conditions should be available in a form that customers can consult before completing the purchase.

Where a customer is offered add-on products such as content subscriptions, insurance or financial services, these should be presented as optional and the customer's explicit consent should be obtained. Bundling that ties access to a basic connectivity service to unrelated add-on products is discouraged unless the customer is given a meaningful choice.

Retailers play a central role in the operational implementation of SIM registration rules. The code reinforces the expectation that identification documents must be verified against the applicant in person, that the identification data captured must correspond to the actual holder of the SIM, and that biometric or other verification tools provided by the operator must be used as intended.

Practices such as pre-registration of SIMs against third-party identities, bulk activation without corresponding customer presence and re-use of the same identification against multiple subscriptions beyond permitted limits are treated as serious breaches. Retailers found to have engaged in such practices may face suspension of their authorisation and, in serious cases, referral for further action.

The code addresses in-store marketing materials, price displays, posters and other communications used in the retail channel. Materials should be accurate, up to date and consistent with the operator's official terms. Where promotional pricing is displayed, key restrictions such as validity, applicable products and geographic scope should be clearly indicated in the same field of view.

Retailers should not display materials from operators that they are not authorised to distribute in a way that could mislead consumers about the range of services available, and should not offer discounts or promotions that have not been approved by the operator whose brand is displayed.

Retailers frequently handle personal data during the sale and activation of SIMs, including identification documents, contact details and, where applicable, biometric samples. The code reinforces that such data must be handled only for the purposes of registration and activation, that it must be transmitted securely to the operator, that paper documents used to capture data must be stored securely and destroyed when no longer required, and that personal data must not be used for the retailer's own marketing without a proper legal basis and appropriate consent.

Operators are expected to provide retailers with tools and training that support compliant data handling, and to include appropriate data protection provisions in their distribution agreements.

Retailers are expected to provide basic after-sales support, including handling straightforward queries, assisting customers with initial troubleshooting and escalating more complex issues through the operator's designated channels. Customers should be informed of the operator's official complaint channels at the point of sale and should not be discouraged from using them.

Where a customer complaint arises from the retailer's own conduct, the retailer is expected to cooperate with the operator's investigation and to implement corrective measures where required. Persistent or serious complaints may trigger a review of the retailer's authorisation to distribute the operator's products.

The code provides for a graduated approach to enforcement. Minor breaches may be addressed through warnings and required corrective action, while more serious breaches may lead to suspension of the retailer's authorisation, revocation of individual retail points and, in the most serious cases, referral to other authorities. Operators are expected to monitor the conduct of their distribution channel and to act promptly on evidence of non-compliance.

The regulator may conduct or commission inspections of retail outlets to assess compliance. Retailers are expected to cooperate with inspections and to provide the requested information. Aggregated inspection findings may be used to inform future regulatory action and to raise the standard of the retail channel more generally.

For operators, the code requires a coherent programme covering the selection, training, monitoring and support of retail partners. Distribution agreements should be updated to reflect the code, staff and agents should receive training on both the substance and the operational implementation of the code, and internal monitoring should be capable of identifying and addressing non-compliance promptly.

For retailers, the code should be reflected in point-of-sale procedures, staff training, marketing controls and record-keeping. Retailers that consistently demonstrate high standards can position themselves as preferred partners for operators and can benefit from more stable commercial relationships.

Lex Civora advises operators and distribution partners on the interpretation and implementation of the code, on the design of distribution agreements and training programmes, on responses to regulator inspections and enforcement actions and on the alignment of the code with related consumer-protection and data-protection obligations.