Connected on arrival: the regulatory puzzle of the travel eSIM

Chiara Garbellini

2 hours ago

6 min read

Look around any international conference today and a good share of the room will be online on a travel eSIM. That was certainly true at the International Institute of Communications (IIC) Annual Conference in Kuala Lumpur last month, where I joined Graeme Di Rollo, Senior Legal Counsel at Airalo for a fireside chat on a question regulators across the world are now grappling with: how should a product that is global by design be regulated by authorities that are, by definition, national?

This piece draws together the main themes from our conversation.

From airplane mode to connected on arrival

Not so long ago, the routine on landing in a new country was the opposite of what it is today. Travellers had three options: switch mobile data off and hunt for Wi-Fi; queue at the airport for a local SIM, losing access to their home number for the trip; or leave roaming on and hope for the best.

Leaving roaming on is how bill shock happens. Earlier this year, a small business owner from Manchester took his family to Marrakech and came home to roaming charges of more than £42,000, after his daughter spent around eight hours on TikTok. His business contract left data roaming outside Europe uncapped, a term he had not realised applied. The charges were eventually waived, but only after the case made national headlines.[1] Cases this extreme are rare, but the fear of them meant many of us got used to keeping our phones offline abroad.

Travel eSIMs have changed this within a few years. Travellers buy a data plan before they leave, install it on their phone and connect to a local network as soon as they land, with the price known and paid upfront. Juniper Research estimates that travel eSIM users will grow from 40 million in 2024 to over 215 million by 2028, and that in 2024 roaming cost subscribers an average of $8.57 per gigabyte, against $5.50 for travel eSIM users: a saving of around 35%.[2]

Value shared across the chain

With a room full of delegates who had flown into Kuala Lumpur from around the world, many of them on a travel eSIM, my first question to Graeme was who actually benefits when a traveller connects on arrival. The traveller is the obvious answer: upfront pricing instead of bill shock, no physical card to swap, and a home number that stays active for calls and texts.

The benefit to mobile operators is less obvious. Travel eSIM providers such as Airalo do not usually own networks. They buy wholesale capacity from local operators, and their customers use those networks. This turns demand that would otherwise be lost, to phones with roaming switched off or to hotel Wi-Fi, into paid wholesale traffic. Airalo sees its marketplace as an extra sales channel for operators, bringing more paying travellers onto their networks, rather than a replacement for roaming.

Destination countries benefit too. A visitor who is online from the moment they land can pull up an arrival card, book a ride, find their hotel and message the people they are meeting. That spending in the local economy starts at the airport, not at the first Wi-Fi hotspot.

For mobile operators, the commercial question is how much of this demand is genuinely additional, and how much replaces existing roaming or tourist SIM revenues. Understanding that balance, and how it changes with wholesale pricing and customer behaviour, is central to deciding how to participate in the market.

A borderless product meets national rules

The difficulty is that a global service is being regulated country by country. For a regulator, this raises a set of practical questions:

Framework: does the travel eSIM need rules of its own, or does it fit within existing ones?
Licensing: does a provider need its own licence, or can it rely on operators already licensed in the country?
Identity and lawful access: how should SIM registration rules, designed for a counter and an ID document, apply to a customer who signs up through an app before they arrive? And can authorities identify a user when the subscriber identity is foreign and the provider sits offshore?
Consumer protection: how do travellers get transparent pricing and redress from a provider outside the regulator’s reach?
Permanent roaming: what happens when a connection meant for a two-week trip is used month after month as a de facto domestic line?
Competition and investment: to what extent do travel eSIMs expand demand or substitute for existing services, and do differences in regulatory obligations create a material competitive advantage?

Answering these questions requires more than deciding which regulatory category a provider falls into. It means establishing how the service is delivered, which obligations already apply along the supply chain, and where any gaps remain. It also means testing whether proposed requirements would address those gaps effectively, and at what cost to consumers, providers and local operators.

Approaches already differ, even within South-East Asia. The Malaysian Communications and Multimedia Commission (MCMC) has just closed a consultation on international roaming-based connectivity, including through eSIM, covering licensing, roaming duration limits, identity checks and consumer protection.[3] In Thailand, new rules on tourist SIMs are already in force. Since August 2025, tourist SIMs can be used for a maximum of 60 days, and topping up credit does not extend that period. To keep using the line, the visitor has to register again with the operator using their passport.[4]

Graeme’s central argument was that regulation should be proportionate and based on how a connection is used, not on the technology itself. An eSIM is simply a different way of delivering a network profile to a device. What matters is who the customer is and why they are connecting. He distinguished three broad cases: short-term travel, continuing domestic connectivity (often described as permanent roaming) and IoT services, where the user is a device. A single rulebook for all of them risks being too burdensome for the traveller, not demanding enough for the rest, or both.

In practice, for genuine short-term travel, Airalo’s view is that the established international roaming framework should remain the baseline, because the traveller already connects through a licensed local network subject to local rules, including on lawful access.

Is common ground realistic?

Our final question was whether harmonisation is achievable, or whether fragmentation is the permanent reality of a borderless product meeting national regulators. Full uniformity is unlikely: the market is young, and some regulators are moving faster than others. But a common baseline of shared definitions and principles is realistic, and telecoms has a strong track record here. International roaming itself works because operators agreed common standards and settlement processes, largely through the GSMA. The GSMA’s eSIM specifications made travel eSIM possible at scale. And the EU’s Roam Like at Home rules, in place since 2017, show that jurisdictions can agree common principles and safeguards while leaving room for national implementation.

Graeme identified three areas where common ground would make the biggest difference: an agreed definition of a genuine travel service, from which most other questions follow; verification methods that countries are willing to recognise, so that a traveller visiting three countries in a fortnight does not register three times; and a clear consumer protection baseline on prices, support and redress. A traveller moving between Malaysia, Singapore and Thailand in the same week should have a consistent, predictable experience. Getting there would need enough common ground to keep the service simple, but not identical rules in every country.

Looking ahead

Travel eSIMs have largely solved one problem: for the travellers who use them, a £42,000 roaming bill is no longer a realistic risk. The harder questions are regulatory. A single connection can now involve a network in one country, a provider in another and a traveller from a third, while most of the rules that govern it were written for a single national market.

Much will depend on how regulators define the service. If they draw a clear line between genuine travel and domestic use, they can protect consumers and lawful access while keeping a service travellers clearly value. If they do not, travellers could find themselves back where they started, switching their phones off at the border. The MCMC’s conclusions will be one of the first signals of where the region is heading, and other regulators are working through the same questions.

For eSIM providers the practical task is to identify where regulatory changes could alter market access, compliance costs or the viability of their service model. For operators, it is to assess the balance between additional wholesale demand and substitution away from existing revenues. For regulators, it is to establish which risks require intervention and whether proposed obligations are proportionate. These are questions of economics as well as compliance.

Chiara Garbellini is a Principal Consultant at DT Economics. She is a regulatory economist with expertise spanning telecoms, digital platforms and payments, advising network companies, regulators and financial institutions across the UK and internationally.

The views and opinions expressed in this article are those of the author and do not necessarily reflect the opinions, position, or policy of DT Economics LLP or its other employees and affiliates.

[1] Ives, A., “Family spared £42,000 roaming bill after TikTok usage abroad”, Travelling for Business, February 2026 (https://travellingforbusiness.co.uk/news/o2-42000-roaming-bill-tiktok-marrakech/).

[2] Business Wire, “Juniper Research: Travel eSIM Users to Grow 440% Globally Over the Next 5 Years; Disrupting Traditional Roaming Market”, April 2024 (https://www.businesswire.com/news/home/20240407967678/en).

[3] MCMC, “Public Consultation Paper on the Use and Provisioning of International Roaming-Based Connectivity Services in Malaysia, Including Through eSIM Solutions”, September 2026 (https://www.skrine.com/insights/alerts/september-2026/public-consultation-paper-on-the-use-and-provision).

[4]Nation Thailand, “New NBTC law tightens rules on SIMs, SMS and foreign calls effective immediately”, August 2025 (https://www.nationthailand.com/news/policy/40054768).