Kenya’s growing scrutiny of how inactive mobile numbers are deactivated and reassigned is raising a wider question for Uganda: what happens when a phone number that has become part of a person’s digital identity is handed to somebody else?
Kenya’s Parliament is examining the issue after the Communications Authority of Kenya Director-General David Mugonyi appeared before the National Assembly’s Public Petitions Committee on October 6, 2026, following complaints over the deactivation and recycling of dormant Safaricom numbers.
The debate has relevance for Uganda, where telecom operators also deactivate and eventually recycle inactive numbers under regulatory rules.
Uganda’s regulations provide that a SIM card that has had no activity, revenue-generating transaction or communication for three continuous months may be deactivated. Before deactivation, the telecom operator is required to give the registered subscriber at least 14 days’ notice. Once deactivated, the number may be assigned to another customer.
That system was designed partly to manage limited numbering resources. But the role of a mobile number has changed dramatically.
A Ugandan phone number can now be linked to mobile-money wallets, bank accounts, social-media accounts, email addresses, online services and password-recovery systems. Losing control of the number can therefore create risks that extend far beyond missed calls and messages.
Uganda’s mobile-money complication
The issue becomes particularly sensitive where a dormant number is connected to an electronic-money account.
Uganda’s regulations specifically recognise the distinction between an ordinary inactive SIM and one connected to an electronic-money account with a balance. Such a SIM is treated as inactive after the period specified under the National Payment Systems Act, rather than simply being treated like an ordinary dormant number.
This is important because Uganda has built a large digital financial ecosystem around mobile phones.
The result is a potential gap between the lifecycle of a telephone number and the lifecycle of the financial and digital services attached to it.
A number may be commercially inactive while information, accounts or recovery credentials associated with that number remain important to its former owner.
That creates a difficult question for regulators and telecom operators: before a recycled number is given to a new subscriber, how effectively can the old user’s digital connections to that number be identified and separated?
Uganda already treats phone numbers as part of identity
The concern is becoming more significant as Uganda strengthens the use of National Identification Numbers across public and private services.
The National Identification and Registration Authority (NIRA) is responsible for maintaining Uganda’s National Identification Register and assigning a unique NIN to registered individuals.
At the same time, the Uganda Revenue Authority has increasingly tied taxpayer records to national identification. URA says individuals are required to update their records with their NIN and active telephone numbers, while its instant TIN service requires a NIN and a working mobile phone number.
That means the phone number is increasingly functioning as more than a communications channel. It is becoming one of the contact and authentication points through which people interact with financial institutions, government agencies and digital platforms.
The risk is not necessarily that a recycled number automatically gives its new owner access to the previous owner’s accounts. Modern platforms have additional authentication and security controls.
The bigger danger is that old accounts, forgotten recovery settings, messaging services or poorly secured platforms may still recognise the recycled number as belonging to the former subscriber.
Uganda’s rules already provide consumer protection
Ugandan subscribers are not without protection.
The Uganda Communications Commission says consumers have a right to be informed before termination of basic communication services.
The country’s regulations also require operators to notify subscribers before deactivating inactive SIM cards.
MTN Uganda, meanwhile, has introduced a “Keep My Number” service for customers who expect to be unable to use their numbers for extended periods, including people travelling or living abroad. The operator says inactive numbers are subject to recycling after 270 days and offers customers a way to preserve their numbers beyond that period.
Such services address one side of the problem: preventing a number from being recycled.
The harder question is what happens after recycling.
The deceased-account question
Kenya’s debate has also highlighted a particularly difficult situation: mobile numbers belonging to people who have died.
The same issue can arise in Uganda.
A deceased person’s number may be connected to mobile-money services, banking notifications, social-media accounts, email recovery and other digital services. If the number eventually becomes eligible for recycling, the challenge is not simply determining whether the SIM is inactive.
It is determining whether the deceased person’s financial and digital relationships with that number have been properly closed, transferred or protected before the number reaches another subscriber.
This is where telecom regulation intersects with banking, electronic-money regulation, data protection and succession law.
A regional regulatory question
Kenya’s experience is therefore relevant beyond its borders.
The country’s recent debate follows a March 2026 High Court decision that recognised the growing importance of mobile numbers to digital identity and prompted the development of additional safeguards around deactivation and recycling.
For Uganda, the lesson is not necessarily that number recycling should stop.
Telecom operators need to recycle numbers because numbering resources are finite. Keeping every inactive number permanently reserved would also create problems for network management and future subscribers.
The more important question is whether the safeguards surrounding recycling have kept pace with the transformation of the mobile number itself.
A number that once existed primarily to receive calls and text messages can now serve as a gateway to money, identity verification, account recovery and digital communication.
That changes the regulatory equation.
Uganda’s existing rules already provide for notice before deactivation and recognise special treatment for SIMs linked to electronic-money accounts. But the growing dependence on mobile numbers across Uganda’s digital economy may warrant a broader review of what happens between deactivation and reassignment.
For consumers, the immediate lesson is simple: an old number should not be treated as disposable until every important account attached to it has been updated or closed.
For regulators and telecom operators, Kenya’s experience offers an early warning.
The challenge is no longer simply finding a new home for an unused telephone number. It is ensuring that when that number changes hands, the digital identity, financial accounts and private information of its former owner do not follow it.
