MPs question Safaricom’s SIM deactivation process as recycled numbers collide with M-Pesa, privacy and digital identity

Kenya’s approach to inactive mobile numbers is facing fresh scrutiny after MPs began examining how Safaricom handles SIM deactivation and the eventual recycling of numbers.

The Public Petitions Committee is looking into concerns raised by Thomson Kerongo and Asiago Stephen over how customers are notified before their lines are disconnected and numbers reassigned to other subscribers. Their petition also raises a more complicated question: what happens when that number is still tied to M-Pesa, banking services, account recovery or other parts of a person’s digital life?

A mobile number can now remain important long after its owner stops using it to make calls or browse the internet. That has made Safaricom SIM recycling a consumer and privacy issue as well as a routine telecommunications process, particularly when the registered subscriber has died or is unable to use the line for an extended period.

Why MPs are questioning Safaricom’s SIM recycling process

The committee is expected to examine how Safaricom applies its procedures when a customer stops using a line. The petitioners have raised concerns over notification, deactivation and reassignment, including the difficulties that can arise when the registered owner is deceased and money remains associated with the number.

The questions facing MPs are therefore broader than whether an operator can reclaim a number that has been inactive. They include whether the customer was given sufficient notice, whether the operator can demonstrate that reasonable attempts were made to reach the registered owner, whether information linked to the old subscriber is properly separated, and whether customers have adequate ways to preserve numbers that remain important to them despite prolonged inactivity.

The inquiry also comes after Kenya’s regulatory and legal framework around mobile numbers changed significantly in 2026. A March 19 High Court judgment treated a registered mobile number as a digital identifier capable of connecting an individual to private information, while the Communications Authority subsequently developed procedures dealing with deactivation, notification and recycling.

TechTrends’ earlier reporting on the court ruling and the regulatory framework established the tension at the centre of the issue. Operators need to manage a finite numbering resource, but the number being reclaimed may still be embedded in a person’s digital identity.

How Kenya’s new number recycling rules work

Under the procedures described in the October 2 parliamentary coverage, a mobile number becomes subject to deactivation and recycling after three months without revenue-generating activity. That includes calls, text messages, data use, airtime top-ups and value-added services.

The operator then has another three months in which it must make efforts to contact the registered owner using the information collected during registration. Thirty days before the notification period ends, the operator is also required to publish the numbers due for deactivation and recycling, alongside notices through its website, other media and a nationwide daily newspaper.

Taken together, that creates a process lasting roughly six months before an inactive number can move towards reassignment. The regulatory approach is significant because it places documentation and notification obligations around an activity that was previously easy to view as a routine network-management function.

TechTrends reported in September that the framework emerged after the High Court ruling and included requirements covering subscriber notification, public notices, data separation, marketing permissions and special circumstances in which an inactive number may need to be preserved. The earlier coverage described the framework in the context of consultation, while the latest parliamentary account says the procedures took effect in September.

The framework also recognises that some people can remain unable to use their numbers for extended periods. Caregivers of people who cannot use their numbers for more than six months can seek to have those numbers whitelisted, with the arrangement renewable annually subject to updated information and confirmation that the circumstances remain valid.

That provision matters because inactivity does not necessarily mean abandonment. Safaricom has previously offered Daima, a service designed to allow customers to keep dormant lines active for longer periods, including people travelling abroad or otherwise unable to use a number regularly.

The existence of such arrangements illustrates why a simple measure of network activity cannot always establish whether a number still has value to its registered owner.

Why an inactive number can still be active elsewhere

The central problem is that a mobile operator sees activity on a network, while the customer experiences the number across an entire digital ecosystem.

A person may stop making calls or using mobile data but still have the number registered with a bank, attached to an online account, used for password recovery or linked to services that send authentication codes by SMS. A business may have the number stored in its customer database. A government service may retain it as a contact detail. None of those relationships necessarily disappear simply because the SIM has stopped generating chargeable activity.

That is why the High Court ruling gave the issue a different legal dimension. TechTrends’ March analysis noted that the court treated the registered mobile number as a digital identifier connected to private information. The question after that ruling was no longer simply how quickly an operator could reclaim unused numbering capacity, but how that process could occur without exposing the previous subscriber’s information or compromising the person who eventually receives the number.

There is also a genuine infrastructure consideration. Kenya needs a functioning numbering system and operators need to manage available number ranges as customer demand changes. Safaricom introduced nine additional number prefixes in August, illustrating one way operators can expand available numbering capacity.

Recycling remains another part of managing the pool, but the regulatory framework places greater emphasis on what happens before and after a number changes hands.

What happens to M-Pesa when a number is deactivated

The M-Pesa connection makes the issue particularly important in Kenya because a mobile number can also serve as the access point to a financial relationship.

Safaricom’s M-Pesa terms provide for an account to be suspended when the associated SIM has been inactive for 90 days. The account may subsequently be archived and the mobile number recycled in accordance with the applicable rules. The terms also state that money held in the account is not lost merely because the account has been archived or the number has been recycled, with the funds remaining available when the customer activates a new mobile number.

That distinction is important. SIM recycling does not mean the new owner of a recycled number inherits the previous owner’s M-Pesa balance. The concern raised before MPs is instead about the practical process of preserving access to money and services connected to the old number, particularly where the original subscriber is no longer able to reactivate it.

TechTrends’ wider M-Pesa coverage also shows why the mobile number has become such a sensitive identifier. Safaricom introduced number masking for M-Pesa transactions in March, reducing the routine exposure of customers’ full phone numbers and requiring an additional verification process where another party needs access to the complete number.

The change reflects a broader effort to limit how much personal information travels with a financial transaction. It also reinforces the point that a phone number is now closely connected to the security and privacy of a customer’s financial activity.

The distinction between number recycling and SIM-swap fraud is also important. They are different processes, but both demonstrate how control of a mobile number can affect access to digital financial services.

A July High Court case involving Safaricom and Diamond Trust Bank found both institutions liable after an unauthorised SIM swap contributed to a KSh4.4 million loss, reinforcing the wider principle that telecom identity controls can have consequences beyond connectivity.

The problem becomes harder when a subscriber dies

The petitioners have given particular attention to deceased subscribers, where the normal assumption that a customer can simply reactivate a number no longer applies.

If a registered subscriber dies, the M-Pesa account does not simply become the property of whoever later possesses the phone or obtains the number. Estate representatives must follow the applicable process to establish their legal right to the funds. Where money ultimately enters the unclaimed-assets system, the Unclaimed Financial Assets Authority provides a separate route through which beneficiaries can make a claim.

The practical concern raised by the petitioners is therefore about the journey between the death of the account holder, deactivation of the associated line, archiving of the account and eventual recovery of funds. Any delay or uncertainty in that chain can make an estate administration process more difficult for beneficiaries, even where the underlying funds remain recoverable.

This is also why the parliamentary inquiry should avoid treating number recycling as a direct mechanism through which customer money disappears. The more precise question is whether the procedures surrounding deactivation and reassignment create avoidable obstacles for people who have a legitimate claim to services or funds associated with the previous subscriber.

The issue has existed within M-Pesa’s estate process for much longer than the current parliamentary inquiry. Safaricom has historically provided procedures for beneficiaries to claim funds belonging to deceased customers, with unclaimed balances eventually falling under the framework administered by the Unclaimed Financial Assets Authority.

The current debate adds another layer because the mobile number itself can now be subject to a formal recycling process while the estate’s claim remains unresolved.

Privacy safeguards must follow the number before it changes hands

The second major issue is what happens to the previous subscriber’s information once the number is reassigned.

Kenya’s regulatory framework requires operators to separate the previous subscriber’s information and services from the number before it is issued to someone else. Personal and cached data associated with the former subscriber is supposed to be securely archived so that it cannot be accessed or inherited by the new subscriber, while records that must be retained under law remain preserved.

That requirement addresses a specific risk created by number recycling. The new subscriber may receive the same sequence of digits, but they should not receive the previous customer’s digital history along with it.

The concern can extend beyond information sitting on the operator’s own systems. A recycled number could remain in third-party databases, contact lists, customer records or account-recovery systems long after the previous owner has stopped using it. A provider can therefore control what happens inside its own network while having limited ability to erase every external record containing the old number.

This is where the regulatory requirement for separating services and removing previous permissions becomes important. A number can be reused, but the identity relationships attached to it have to be severed first.

What the parliamentary inquiry now needs to establish

The committee’s task is ultimately to establish whether Safaricom’s practices match the safeguards now governing inactive numbers.

That means looking beyond the final act of reassignment. MPs will need to examine how Safaricom identifies inactivity, how it contacts customers, what evidence it retains showing that notification efforts were made, how public notices are handled, how numbers are treated during the notification period and what technical controls are applied before reassignment.

The committee will also need to hear from the relevant regulators and consumer representatives, particularly on whether customers understand how long they have before a number can be recycled and what options exist for people who need to preserve a line during prolonged inactivity.

For customers, the practical lesson is straightforward: an unused number can remain important even when it is generating no network activity. Anyone keeping an old number linked to banking, M-Pesa, account recovery or authentication should make sure the number remains active or is formally preserved through the mechanisms available from the operator.

The larger issue, however, sits with the system. Kenya’s mobile ecosystem was built around the assumption that a phone number could serve as a convenient, persistent identifier. The High Court ruling, the Communications Authority’s safeguards, M-Pesa’s privacy controls and now the parliamentary inquiry all point to a problem that operators and regulators must address: a number can be reused by the network without the digital relationships surrounding it being automatically ready to move with it.

The Public Petitions Committee will now have to determine whether the safeguards are working as intended and whether additional protections are necessary. For Safaricom, the scrutiny comes at a time when its network identity systems sit underneath a much wider range of financial and digital services than a conventional mobile line once did.

The outcome will matter beyond one operator. If Parliament finds that customers need stronger notification, clearer preservation mechanisms or tighter controls before numbers change hands, the recommendations could shape how Kenya manages the boundary between a scarce telecommunications resource and the digital identity attached to it.

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