Displaced and disconnected across Asia and the Pacific
People forced to flee struggle to access meaningful connectivity and digital financial services. The Innovation Service is exploring why.
By Tala Budzizsewski, Innovation Officer
Balance restrictions on online accounts. Inability to register a SIM card using their available identification. These are just a couple of the legal and regulatory barriers preventing refugees around the world from accessing safe and sustained connectivity. This matters because, increasingly, access to connectivity and digital services is essential for everyday life. Being displaced is bad enough; being disconnected, in addition, drastically curtails refugees’ capacity to rebuild their lives in a new place. UNHCR’s new Digital Transformation Strategy recognizes digital inclusion as key to our protection work.
Among the numerous challenges hindering forcibly displaced people from getting and safely using connectivity, this lack of enabling legal and regulatory environments is a basic starting point. It makes it hard for refugees to access SIM cards and financial services in their own names, restricting their capacity to connect with others, use vital services, and make informed decisions. The UNHCR Innovation Service’s Displaced and Disconnected research initiative is designed to gain a better understanding of these barriers globally.
Our research in Asia and the Pacific — building off investigations undertaken from 2019 to 2022 across Africa and the Americas — was conducted in collaboration with local researchers and experts. It examines the legal frameworks governing refugee connectivity in several countries in the region — Philippines, Indonesia, Malaysia, and Papua New Guinea, to date. Such frameworks are just the beginning; their application, and the specific circumstances of refugees in a given context, can make all the difference. This research explores those contextual nuances, which may differ significantly from regions explored earlier in this series. It has unearthed regional trends and specific challenges, enabling us to draw key lessons and propose recommendations for extending the lifeline of connectivity to forcibly displaced and stateless communities across Asia and Pacific.
The regional context
In Asia and the Pacific, two protracted crises — in Afghanistan and Myanmar — as well as continued conflict, climatic extremes, and impacts of other natural hazards have led to record high levels of forced displacement and ongoing risks to marginalized groups. The region now hosts more than 14 million forcibly displaced and stateless people. In fact, around 2.5 million stateless individuals — more than half the world’s recorded stateless population — live here.
Many countries in the region are not signatory to the 1951 Refugee Convention, which affects the legal status of displaced people and their options for accessing services. Although the legal and regulatory frameworks governing access to asylum and rights for refugees vary widely across the region, certain common threads can be found in terms of connectivity access.
Barriers to registering a SIM
Across the four countries included in this research, SIMs must be officially registered and legal identity documents must be presented to complete that registration process. In the Philippines, this has only been the case since 2022, when a law was passed requiring registration and ending previously unhindered access to prepaid SIM cards. Which ID documents are accepted and how this influences access to connectivity, however, varies widely across the region.
In Malaysia, for instance, UNHCR-issued IDs are not accepted for the purposes of SIM registration, while in Indonesia, only a recent change in regulation means those with UNHCR-issued IDs are able to use them for this purpose. In Papua New Guinea, such IDs are not accepted; however, people without an accepted form of ID are able to register a SIM if they are accompanied to the registration site by a “reputable person” from the community. On the other hand, the government of the Philippines issues IDs to recognised refugees and stateless people that can be used to register a SIM.
Risky workarounds
Many displaced and stateless people in the region are ultimately able to access SIM cards, but only after resorting to a variety of measures to avoid the above barriers. These workarounds, in many cases, involve obtaining SIMs from a friend or broker who is a citizen of the country. This approach exposes refugees to a wide range of risks, ranging from uncertainty as to how dependable the connection is (it may be lost, for instance, because the SIM is deactivated), to inability to control the cost or form of that connectivity (if, for example, the mobile coverage plan can only be changed by the registered owner of the SIM), to elevated fees charged by brokers, to potential extortion.
Other workarounds — for instance, using more easily accessible short-term SIMs and changing them regularly — also lead to inconsistent access to connectivity and unfeasible access to services. These issues make it difficult for users to access their services and accounts that are linked to a phone number, and also to keep in regular contact with their family members and service providers, including UNHCR.
The legal status of each individual, or where they happen to be in their displacement journey, can have a significant impact on connectivity access. As mentioned above, recognised refugees and stateless individuals in the Philippines, for example, benefit from government-issued ID cards that can facilitate SIM access. However, this is not the case for documents issued to asylum seekers and stateless applicants awaiting decisions on their status. Across the region, asylum seekers who have not yet registered with UNHCR and therefore are not in possession of UNHCR-issued ID cards may have even less access to documentation to gain access to connectivity.
Barriers to accessing digital financial services
The Know Your Customer and Customer Due Diligence processes involved in opening bank and mobile money accounts represent further challenges for displaced and stateless people. The documentary evidence needed for the relevant checks typically cannot be met, even if the IDs available to displaced people are accepted. This is especially true for people forced to flee from countries — such as Iran and Myanmar — that tend to require enhanced due diligence checks.
Even when displaced individuals can get bank or mobile money accounts, they might only be able to access very restricted services. Some individuals in this position, for example, are only allowed access to basic accounts that have a balance cap. This cap can be as low as 140 USD, for instance, in Indonesia. Products with more useful functionalities — higher balances, for instance, or loans, transfers to other bank accounts, and higher transaction limits — are virtually impossible to access without meeting more stringent documentation requirements.
Documentation hurdles, multiplied
On top of the initial ID barrier, the additional documentation requirements for verification processes to access SIM cards or financial services are very hard for displaced people to satisfy, and the inflexibility of these requirements gives them little wiggle room. Lease agreements, national ID numbers, birth certificates, and work permits are among the papers commonly required to register a SIM, open a bank account, sign up to a mobile wallet, or, indeed, to use these tools. In Malaysia, for instance, multifactor authentication only accepts a limited range of documentation — which is almost never accessible to refugees and asylum seekers. In the event that a displaced person does have a mobile wallet account, the requirements to use multifactor authentication makes certain transactions virtually impossible.
Displaced people in the region very rarely have access to any of these documents, let alone the multiple types required to satisfy these processes. Inflexibility in these requirements is a key barrier to displaced and stateless individuals accessing digital services.
Contextual nuance
It’s essential to recognize that access to connectivity and digital services does not only depend on regulatory barriers. It very much hinges on the application of those frameworks as mediated by service providers, and the experience of those barriers as navigated by displaced individuals. Key issues here include a lack of knowledge on the part of service providers, risk aversion from these providers, and a dearth of products and processes designed with the needs of displaced people in mind.
In Indonesia, for example, the recent change in regulations mentioned above now allows UNHCR-issued ID cards to be used for SIM registration. However, this change has not been widely communicated to vendors, who are unfamiliar with these IDs. As a result, UNHCR-issued IDs are commonly rejected. Meanwhile, in Malaysia, while there are legal avenues for displaced people to open certain bank accounts with their own documents, each service provider retains the right to provide services at their own discretion or request additional checks. This approach can exclude refugees from accessing accounts — for example, if they are considered to be a high-risk client from a black- or gray-listed country, and cannot satisfy enhanced due diligence requirements.
Connectivity opportunities: Positive steps across the region
Despite these numerous challenges, authorities, service providers, and civil society have taken significant steps toward creating a more enabling environment for refugee connectivity. All countries reviewed in this research have demonstrated practices that could enhance the digital inclusion of displaced and stateless people. Dismantling the legal and regulatory barriers these communities face is a crucial step toward enabling them to contribute to their new contexts.
In the Philippines, the provision of government-issued IDs to recognised refugees and stateless people, and the inclusion of these groups in the ongoing roll out of the Philippine Identification System (PhilSys) — which will provide a national ID for Filipinos and foreigners alike — means many displaced people can enjoy relatively broad access to digital services. Although these benefits do not extend to asylum seekers and stateless applicants awaiting status decisions, they are excellent steps toward greater inclusion. The more relaxed documentary requirements to open mobile money accounts, as compared to traditional bank accounts, has also enabled greater access to financial services (even if those services are limited).
The recent change in Indonesia enabling UNHCR-issued ID holders to use those documents to register SIMs not only broadens the opportunities for more consistent, safer connectivity — it also expands access to digital financial services. A SIM that is officially registered in one’s name can be used to open simple accounts on mobile money platforms, without much further documentation. Although a valid passport is required for more comprehensive services, a registered SIM remains an important entry point for basic banking options.
In Malaysia, the Central Bank has issued guidance stipulating that a letter or document issued by a UN body can be used for proof-of-identity purposes. This means that registered asylum seekers and refugees are now able to open basic bank accounts, enhancing access to safer remittance options and small-scale transactions.
In Papua New Guinea, meanwhile, the option to register a SIM if accompanied by a person with a valid ID has created opportunities for humanitarian organizations to arrange supported-registration initiatives. Save the Children, for example, carried out a SIM registration exercise alongside a pilot to test the use of mobile money for cash transfer programming. This approach enabled safer transfers while providing participants with the longer-term benefit of a SIM card and mobile money account.
Recommendations going forward
Such approaches demonstrate ways in which concerns around criminal communications, limited financial due diligence, money laundering, and terrorism financing can be mitigated while still creating an enabling environment for forcibly displaced people to access connectivity and digital services. As we can see from the Papua New Guinea example, these steps can also broaden the avenues for humanitarian organizations to safely deliver support to marginalized communities.
Key steps to continue enhancing the legal and regulatory environment across the region include:
1. Ensuring a wider diversity of ID documentation — whether government- or UNHCR-issued, depending on the context — is made accessible to, and accepted as valid proof of ID for forcibly displaced people at different stages of their journeys. Such documentation could include: asylum seeker certificates, UNHCR-issued IDs for both recognised and as-yet-unrecognized refugees, and certificates for stateless person applicants, among others.
2. Expanding opportunities available to forcibly displaced and stateless people to meet due diligence and identity check that enable access to a broader range of financial services, higher balance ceilings, and higher transaction limits for both traditional and mobile money accounts
3. Working with financial service providers to develop processes and products that better meet the needs of forcibly displaced people, recognizing both the limitations they face and their potential as an untapped customer base that could contribute to local economies.
4. Advocating for governments and service providers to issue clear guidance on new and existing regulations that is well communicated and cascaded to points of service, to enable more consistent application of regulations that support access to SIM cards and bank and mobile money accounts.
5. Supporting government regulators and service providers to ensure new policies, regulations, and systems related to connectivity and digital financial services are designed inclusively, to consider the situation and needs of forcibly displaced people.
Addressing these legal and regulatory challenges is just part of the work to be done to increase refugees’ access to connectivity and digital services. Other barriers facing forcibly displaced and stateless communities include poor connectivity infrastructure (this is the case, for example, in rural locations in the Philippines), a lack of sufficient funds to open accounts (a challenge that is found across all contexts), and limited digital literacy, particularly for women. The latter issue — a factor in the digital gender divide facing forcibly displaced women and girls — is a key barrier in Papua New Guinea.
UNHCR is collaborating with the International Telecommunication Union (ITU), GSMA, and a growing coalition under the banner of a Global Refugee Forum pledge on Refugee Connectivity to collectively harness the expertise, resources, and investment needed to address these diverse barriers and deliver meaningful connectivity to forcibly displaced and host communities around the world.
Read in depth about the legal and regulatory barriers to refugee connectivity in Asia and the Pacific, and around the world, here. Interested in supporting our work to address these, and other, barriers? Find out more about our connectivity coalition here, and contribute toward the GRF pledge.
