2023年6月24日发(作者:)
GSM Association
Embedded SIM Task Force: Requirements & Use Cases
Non-Confidential White paper
Embedded SIM Task Force Requirements and Use Cases
1.0
21 Feb 2011
Security Classification – NON CONFIDENTIAL WHITE PAPER
Copyright Notice
Copyright © 2011 GSM Association
Antitrust Notice
The information contain herein is in full compliance with the GSM Association’s antitrust compliance policy.
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GSM Association Non-Confidential White paper
Embedded SIM Task Force: Requirements & Use Cases
Table of Contents
1 Introduction
1.1 Overview
1.2 Problem Statement
1.3 Approval
1.4 Scope
1.5 Definition of Terms
1.6 Interchange of terms: UICC / USIM
1.7 Document Cross-References
2 Assumptions & Principles
2.1 Assumptions
2.2 Principles
3 eUICC State Model
3.1 Valid eUICC States
3.2 State Transition Diagram
4 Role and Trust Definitions
4.1 Role Definitions
4.2 Trust Relationships
4.3 eUICC Certification
5 Use Cases
5.1 Vertical Use Cases
5.1.1 Overview of the use cases
5.1.2 UC1: Provisioning of multiple M2M subscriptions
5.1.3 UC2: Provision of first subscription with a new connected device
5.1.4 UC3: Change of subscription for a device
5.1.5 UC4: Termination of a subscription for a consumer device
5.1.6 UC5: Subscriber transfers subscription between devices
5.2 Functional Use Cases
6 Processes
6.1 UC1: Processes for (multiple) M2M use cases
6.1.1 UC1 a) Provisioning an M2M subscription on a new device
6.1.2 UC1 b) Process for changing a M2M subscription
6.1.3 UC1 c) Process for fallback to a previous subscription
6.2 UC2: Provision of first subscription with new device
6.2.1 UC2 a) Provision of device consumer selects MNO
6.2.2 UC2 b) Provision of enterprise devices
6.2.3 UC2 c) Device with first subscription pre-loaded
6.3 UC3: Change of Subscription for a Consumer Device
6.4 UC4: Termination of a Subscription for a Consumer Device
6.5 UC5: Subscriber transfers subscription between devices
7 Requirements
7.1 Lifecycle requirements table
7.2 Service Management Requirements Table
7.3 Communications Requirements Table
7.4 Robustness Requirements Table
7.5 Liability Requirements Table
7.6 Market Requirements table
7.7 Security requirements table
7.8 Certification Requirements Table
8 Ongoing Topics
9 Document Management
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1
1.1
Introduction
Overview
The GSMA Embedded SIM Task Force created this document. It develops Use Cases and
Requirements for the “enhanced, remote management” of a UICC, which is embedded in a
communication device, i.e. where the UICC is not easily accessible and replaceable. This
type of UICC is compatible with Machine-to-Machine (M2M) applications. The UICC may be
embedded at the manufacturing site in advance depending on the country and network
operator, and is compatible in a variety of end-user equipment. In these scenarios, there
may be a requirement to change a subscription easily, this is currently achieved by
physically changing the UICC.
The purpose for defining these requirements is to provide ease of use and deployment
benefits for end users/consumers and thereby stimulate the M2M device sector. A further
intent is to enable the creation of common standards and processes for remote
management of subscriptions on UICCs, such that fragmentation across the industry is
effectively discouraged and prevented.
The use cases will describe a technical solution for “enhanced remote management” for the
future of embedded UICCs. This includes reusing established international standards to
maximise acceptance worldwide.
1.2 Problem Statement
Since the inception of GSM, the UICC/SIM card has successfully provided Authentication
and Authorisation capability to allow user devices access to networks. This illustrates users
accepting the use of UICC/SIM cards to transfer their network subscriptions from one device
to another. The creation of higher capacity cards in terms of memory and processing power,
work is underway to increase the scope of the UICC card and to provide additional services
supported by technologies such as Smart Card Web Server, InterChip USB, and Single
Wire Protocol (NFC).
It is noted that new business models and usage scenarios, primarily driven by M2M,
struggle when supported by the traditional UICC/SIM card. For example:
By installing physical UICC/SIM cards, the user is connected to a specific network,
as the card only provides access to one network. Should the user wish to (or need
to) use another network, then they or the M2M service provider has to fit another
card in his/her device.
Changing UICC/SIM cards maybe problematic, noting that M2M equipment may be
remotely located, and/or hermetically sealed. It should be noted that where the
UICC/SIM is not intended to be sealed and inaccessible, the portability of traditional
form factor UICC/SIM cards is perceived to be a user benefit.
Non-standard provisioning and re-provisioning methods are being defined and used.
These present security implications and a risk of fragmentation within the industry.
New remote provisioning / re-provisioning mechanisms are required to support the new
business models and usage scenarios.
Fragmentation of solutions leads to additional complexity, further costs within the industry
and inhibits user choice. To prevent fragmentation across the industry the new mechanisms
should be standardised by appropriate Standards Developing Organisations. These should
comply with and be auditable against relevant security standards.
The intention of this document is to enable the development of solutions combined with any
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provisioning of credentials to a UICC in a secure manner without necessarily having to
transport the UICC back to a secured and accredited physical location.
1.3 Approval
This document has been approved by the GSMA Strategy Committee for submission to
ETSI SCP.
1.4 Scope
The primary intention of the requirements expressed in this document and any solutions that
meet them, is to facilitate the M2M and Embedded Mobile (see Definition of Terms) market
segments.
The scope of solutions is intended to cover requirements for the complete provisioning
ecosystem.
1.5 Definition of Terms
Note definitions taken from 3GPP 21.905 V10.2.0. Following the completion of a review, any
duplicates with 3GPP 21.905 V10.2.0 shall be removed.
Term
Administration Profile
Description
Profile enabled to allow a recovery point during a transition should failure
occur.
This profile shall be able to coexist with an operational profile but shall not be
used for purposes other than administration of the eUICC by the SM. .
Combination of data required to provision a eUICC so that it can be
authenticated by an MNO or other service a Subscription
Manager. Such credentials may additionally support mutual authentication
and confidential communications. MNO credentials may include algorithms,
Ki/K, and IMSI stored within a network access application such as a
SIM/USIM/ISIM. (Note: this definition covers neither contractual nor billing
activities nor all aspects of the MNO's subscriber administration.)
CDMA 2000 Application on UICC. An application residing on the UICC used
for accessing CDMA network services.
Device, which is capable of providing access to 3GPP System services to
users, either alone or in conjunction with an UICC. Can cover embedded
modules and other device form factors.
The operator/MNO whose credentials were active in the device, but are no
longer active after the provisioning process.
Used to denote the emerging service category characterised by
combinations of devices and services supported by an embedded 3GPP
network access capability that is not traditionally considered mainstream
mobile network devices.
A small trusted hardware component, which may be soldered into mobile
devices (as per MFF1 and MFF2), to run the secure network access
application(s) (e.g. GSM Subscriber Identity Module application) and enable
the secure changing of subscription identity and other subscription data.
Performs the role of a traditional UICC.
Term used for clarity within this document and does not necessarily
introduce a new component. .
A set of information provided by the eUICC supplier to allow future
provisioning of the eUICC. This shall contain at least the following:
- A persistent identifier for the eUICC (see also ICCID).
- A secure association between the persistent identifier and lifetime
characteristics of the eUICC (e.g. Operating System version,
cryptographic and downloading software)
- A means for at least one Subscription Manager to authenticate the
eUICC against this persistent identifier
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Credentials
CSIM
Device/Terminal
Donor Operator
Embedded Mobile or
Embedded Device
Embedded UICC
(eUICC)
Embedded UICC
(eUICC) Credentials
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Any specific Subscription Manager will also need its own cryptographic keys
to establish confidentiality and mutual authentication between the eUICC and
the SM (see Credentials). Such credentials have to be securely delivered to
a specific by the eUICC supplier, or by secure handover
mechanisms between SMs.
EMP GSMA Embedded Mobile Programme
first subscription Subscription provided by an MNO used for operational purposes (network
access providing connectivity to telecom and value added services) after
issuance of the eUICC.
Form Factor Manifestation of UICC. Specified in references 1 and 15.
Equipment in which the module is inserted during assembly. Examples
Host Equipment
include: Meter, Car and Camera.
Unique number for the UICC hardware that is stored on the UICC and – for a
conventional UICC - also engraved upon it. Defined according to ITU-T
recommendation E.118.
Note: An example solution for the eUICC is to have an ICCID file that is
associated with the current active MNO, but this may change if the active
ICCID
MNO changes.
Regardless of solution, the eUICC shall also have a standardised unique
persistent identifier. The numbering scheme used for this purpose should be
encoded such that data about the eUICC can be derived in a similar manner
to the existing E.118 scheme.
International mobile subscriber identity (IMSI). Unique identifier owned and
IMSI issued by Mobile operators to SIM applications to enable devices to attach to
a network and use services.
Either a first set of valid MNO credentials for immediate use or a set of
Initial Credentials /
credentials for a trusted service provider (Subscription Manager) who can
Provisioned State
then download selected MNO credentials.
ISIM IMS Services Identity Module
Machine to Machine, normally applied to services such as Utility metering
where no traditional user or user interface is provided. Such services are
M2M
expected to operate stand-alone and physical access by MNOs and Service
Providers is often limited.
Form of device/terminal manufactured for embedding within larger host
Module
equipments.
MNP Mobile Number Portability
NAA Network Access Application
OTA over the air
Combination of MNO credentials, data and applications to be provisioned on
Operational Profile to a eUICC. This may include MNO, third party and user applications and
data. Only one operational profile can be active at any point in time.
The act of loading credentials onto a UICC/eUICC. For UICC typically
undertaken in Personalisation centres (see Trusted Environment).
Personalisation
Note: Provisioning and Personalisation have been used interchangeably in
this document.
Locks the UICC and SIM applications until the correct code is entered. If the
PIN PIN is entered incorrectly 3 times in a row, the UICC will be blocked requiring
a PUK.
A set of rules defined by the MNO that controls the usage of its own
credentials. Policy Control consists of determination of the rules to apply and
Policy Control
enforcement of those rules. Each MNO is responsible for its own rules,
Function / PCF
although an SM can execute these on a MNOs behalf. SM is responsible for
enforcement on behalf of the MNO.
Set of security and functional objectives, for the eUICC.
To allow SMs to perform their function there needs to be alignment on
Protection Profile
common agreed protection profile(s) across MNOs. Note there may not be a
single unique protection profile across all operators.
Within this document, provisioning typically refers to the loading of profiles,
Provisioning
credentials, data and applications into a eUICC/USIM. This does not remove
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the need for „classical‟ provisioning of network HLR and in
general the requirements for provisioning of network elements is not
described in this document.
Note: Provisioning and Personalisation have been used interchangeably in
this document.
The provisioning subscription enables a device access to a mobile network
for the purpose of management of MNO subscriptions on the eUICC. An
provisioning administration profile could be used for this purpose.
subscription
Note: a provisioning subscription may not be required where provisioning is
executed using an alternative tethering or direct-wired access.
PUK PIN Unblocking Key.
The operator/MNO whose credentials become active in the device after the
Recipient Operator
provisioning process.
Portfolio of choices offered by operators and service providers to a user,
Services
functionality offered to a user.
SIM application contains the unique identifier of the mobile user (IMSI),
security authentication and ciphering information, temporary information
SIM
related to the local network, a list of the services the user has access to and
two passwords (PIN for usual use and PUK for unlocking)
SIM Portability Ability to move UICC/USIM between devices
An entity (associated with one or more users) that is engaged in a
Subscription with a service provider. The subscriber is allowed to subscribe
Subscriber and unsubscribe to services, to register a user or a list of users authorised to
enjoy these services, and also to set the limits relative to the use that
associated users make of these services
Describes the commercial relationship between the subscriber and the
Subscription
service provider.
Subscription Entity managing credentials and data on eUICCs on behalf of specific /
Manager(s) (SM) multiple MNOs; as described in 4.1 (Roles and Trust definitions).
Environment specifically constructed for the personalisation of UICCs on
behalf of MNOs. Should be certified by the GSMA SAS accreditation scheme
Trusted Environment plus additional MNO validation based on contractual relationships.
{Note: eUICCs are expected to receive their Initial Credentials in a Trusted
Environment}
A smart card that conforms to the specification written and maintained by the
UICC ETSI Smart Card Platform project.
Recent definitions (Ref 1) permit soldered versions of UICCs.
Un-trusted
Everything that is not a Trusted Environment.
Environment
Universal Subscriber Identity Module.
Application residing on the UICC used for accessing services provided by
USIM
mobile networks, which the application is able to register on with the
appropriate security
1.6 Interchange of terms: UICC / USIM
The terms UICC and USIM have specific meaning as given in the definitions. In 3GPP
markets to date, the distinction between UICC and USIM (essentially that of hardware/OS
as distinct from software application) has not been significantly relevant, as mostly a
combination of the two has been delivered to market as a package from SIM vendors, in the
same way as previously for 2G SIM cards. Furthermore, colloquial marketing language has
often not accurately used the terms.
If there is an evolution to “eUICC”, the use of the appropriate terms will become important.
There may be a requirement to develop further terms defining differing combinations of
layers within the “eUICC”; e.g. Java and Global Platform as OS and management layers
respectively on top of the native card OS and Security domains. These will become clear
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when business, ownership models and technical solutions become developed to support the
use cases and requirements given in this document.
It should be noted that the varying use of terms UICC and USIM throughout this document
are indicative at an early stage of the split in the “eUICC” of hardware and application
software functionality, but should not be taken as rigid requirements in the future
development of architecture and technical specifications.
1.7
Ref
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Document Cross-References
Document
Number
ETSI TS 102.671
ETSI SCP TS 102.221
TS 22.101 (§13)
TS 21.111
TS 102.224
TS 102.225
TS 102.226
3GPP CT6 TS 31.101
ETSI TS 122.038
3GPP TS 31.111
ETSI TS 102.223
3GPP TS 31.102
3GPP TS 31.103
3GPP2 C.S0065
ISO 7816-1
Title
Smart Cards; Machine to Machine UICC; Physical and logical
characteristics
Smart Cards; UICC-Terminal interface; Physical and logical
characteristics
3rd Generation Partnership Project; Technical Specification Group
Services and System Aspects; Service aspects; Service principles
3rd Generation Partnership Project; Technical Specification Group
Terminals; USIM and IC card requirements
Security mechanisms for UICC based Applications - Functional
requirements
Secured packet structure for UICC based applications
Remote APDU Structure for UICC based Applications
3rd Generation Partnership Project; Technical Specification Group
Terminals; UICC-terminal interface; Physical and logical
characteristic
USIM application toolkit
USIM application toolkit
Card Application Toolkit
Characteristics of USIM Application
Characteristics of ISIM Application
CSIM application on UICC
Physical Characteristics of Integrated Circuit Cards
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2
2.1
Assumptions & Principles
Assumptions
The following assumptions are made in this work.
No.
A1
Assumption
Any solutions implemented supporting these requirements are intended to be used in addition to
existing UICC/SIM standards rather than replace them. The eUICC in which the (U)SIM
application will be installed shall comply with UICC standards contained in the References listed,
with the exception of the removable aspects.
The use of a eUICC shall limit the need for any change in existing personalisation and
distribution models.
Any solution will be applicable to all international agreed standards for Form Factors. Currently
this means ID1, 2FF, 3FF, MFF1, MFF2.
The owner of the eUICC shall have an appropriate obligation to preserve the physical and logical
integrity of the eUICC in such a way that its suitability for secure storage is maintained, and shall
ensure that a similar obligation is imposed on any subsequent owner during any transfer of
ownership of the eUICC.
{Note1: Issued UICC and SIM cards are currently owned by MNOs, it is understood that eUICCs
may introduce new ownership models.}
{Note2: An „appropriate obligation‟ as described above may be legal, contractual, regulatory or of
some other form.}
A2
A3
A4
A5 Any switch from MNO A to MNO B may be limited by the functionality of the eUICC feature set in
accordance to MNO A donor and MNO B recipient roles.
{Note1: This is not referring to any mechanism to prevent switching, but to note that switches
may occur with subscribers losing some services.}
{Note2: This issue should be minimised (hopefully eliminated) by an agreement between all
operators on the set of features the eUICC has to support.}
A6
A7
A new Trust model between entities will need to be established due to the necessary business
processes resulting from the eUICC. This is likely to introduce liability changes.
Any remote provisioning mechanisms must make use of requisite protocols implementing at least
an agreed minimum required security level. Any UICCs that are incapable of being upgraded to
the required level for such protocols and algorithms are deemed to be outside the scope of any
solution and will not be subject to any of the mechanisms described in this document.
{Note1: This will lead to specific technical requirements in terms of security.}
{Note2: Agreement shall be required on the necessary security levels described above. In
general, the minimum level of security must be at least as good as the current industry best
practise for UICCs.}
A8 Not all personalisation may be performed at the same time, and there may remain a split
whereby some or all personalisation will continue to be undertaken prior to the eUICC leaving the
eUICC supplier environment, or combination of the eUICC supplier and Subscription Manager
(SM) entities.
It shall be possible for the SM to manage network access and applications/services on behalf of
the MNO on the eUICC in accordance with the defined policy control functions.
Modifications to the eUICC OS during the in-field lifecycle of the eUICC are out of scope for this
document. However, it is anticipated that any solution to the requirements in this document may
require modifications to existing UICC OSs.
It is not presumed that any deployed solution based on the requirements embedded within this
document should be compliant with all use cases. All described functions; are an example, of
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A9
A10
A11
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No. Assumption
smart metering devices and may not require the implementation of 'transfer subscription', or
'provisioning of a first subscription with a new connected device' use cases, which may permit to
offer a cost effective solution, satisfying level of required features in this particular environment
and keeping the required security level.
A12
A13
Existing regulatory requirements (when apply) should continue being supported as today.
It shall be possible for SMs to manage eUICC Credentials and manage their own credentials in
order to permit Assumptions A9.
Noting that:
All eUICC vendors must be able to securely distribute credentials to one or more SMs;
SM is not a mandatory organisation, it is a mandatory role that can be performed by
many types of organisation;
Depending upon business models and commercial relationships MNOs may use more
than one SM and SMs may interconnect in an appropriate way to permit management of
an eUICC to swap between SMs;
MNOs policies may include which SMs to operate with based on commercial and quality
assurance considerations.
2.2
No.
P1
P2
P3
Principles
The following principles are made in this work:
Principle
Traditional UICC/SIM models will not be affected and will continue to work on existing networks.
Provisioning credentials are always the property of the MNO that supplied them.
Solutions to these requirements shall retain existing or improved levels of user friendliness.
{Note1: Where the device has a human end user, the user‟s experience of first choice or change
of an MNO shall not be less convenient than the current experience of inserting or removing a
UICC/SIM card.}
{Note2: An explicit notification and/or request for action on the part of the human user should be
required prior to the execution of changes on the UICC/SIM card.}
P4
P5
P6
The implementation of any solution to these requirements shall re-use and profile existing
international standards wherever possible minimising the need for additional standardisation.
Current levels of fraud prevention and tamper resistance shall be retained.
The eUICC shall be a component accredited against agreed industry criteria for the secure
storage and management of security-critical data.
{Note: In this context, data means data and applications.}
P7 Issuance and maintenance of all forms of credentials will require trust between the individual
actors involved.
{Note1: Such trust has legal and liability implications that will need to be embodied in formal
relationships.}
{Note2: Accreditation shall be required to support the trust between actors.}
{Note3: Credentials shall only be stored by trusted entities. Operators shall not be obliged to
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No.
P8
P9
P10
P11
P12
P13
P14
P15
P16
P17
Principle
store their credentials where trust does not exist.}
Any solution to these requirements shall maintain existing levels of trust and security in the
GSM/3G/LTE systems.
An MNO should need to maintain only a small number of interfaces to the entities, which manage
personalisation of eUICCs on behalf of that MNO.
Any solution to these requirements shall meet applicable regulatory requirements in relevant
jurisdictions
The goal of the technical implementation is to re-use existing procedures to provision the eUICC
and HLR data wherever possible.
Any solutions to these requirements should be cost effective for all stakeholders.
Any solution to these requirements must be open and equally available to all industry
participants.
Any solution to these requirements shall be globally acceptable, independent of a particular
MNO, country, or region.
Any solution to these requirements must be available to all (including non-members of GSMA) on
FRAND terms.
Any solution to these requirements must meet tests for anti-competitive practises.
As soon as a specific MNO profile (including the relevant (U)SIM application) is active on the
eUICC, this active element must comply with the security policy of the relevant MNO.
{Note: A relevant generic security policy would be provided for MNO consideration by the GSMA
Security Working Group}
P18
P19
There shall be only one active Operational profile on the eUICC during the provisioned state at
any stage in the lifecycle of the eUICC.
There should be an obligation of interoperability for every solution to these requirements, in order
to prevent any disruption in the resulting ecosystem and to preserve the consumer friendliness of
devices and services for every mobile user in all their daily activities.
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3 eUICC State Model
Describes the states in which a eUICC can exist..
Note that the states described are for the eUICC only, not the eUICC in conjunction with any
other entities (e.g. Subscription, which can also describe also the state of entities within
network elements).
3.1 Valid eUICC States
Not all the states will need to be accessed and defined, depending on the lifecycle of the
SIM/USIM applications in the eUICC.
No.
1
State
Pre-Initialisation
Initialised
Description
Manufactured but no credentials stored.
In this state, Physical presence is required to determine whether eUICC is
genuine.
Initial credentials (at minimum, eUICC Credentials) stored.
eUICC can connect to server for purposes of further configuration in an
un-trusted environment.
Optionally, the eUICC credentials become linked to the device‟s IMEI.
2
3 Provisioned Valid Home MNO credentials stored.
eUICC has an active profile for the MNO, which is expected to enable
operational connection to the network.
During the transition from one MNO to another, the eUICC may move
from Provisioned state associated with one MNO to Provisioned state with
the other without going back to Initialised state.
Note: In the situation where the subscription associated with the eUICC
has been deactivated in the network, the eUICC will still be in Provisioned
state.
4 Disabled Presents no valid MNO credentials, but some eUICC credentials may stay
valid (at least the eUICC persistent identifier)
This state will not allow device to attach to a mobile network, since it does
not have an active profile and cannot acquire one. It is thus considered to
be „end of life’.
The eUICC should have the capability to enter the Disabled state if
removed from the device in which it was embedded.
{Note: the request to go in this state has to be authenticated in order to
prevent Denial Of Service attack.}
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3.2 State Transition Diagram
This is included for guidance and not a firm requirement on valid / invalid state
transitions.
Transition between states is equivalent to processes such as activate, suspend
and delete.
Figure 1: Suggested eUICC State Transition Diagram
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4
Role and Trust Definitions
Role Definitions
Description
A supplier of devices; these devices include wireless modem functionality
to communicate over wide area networks run by MNOs, thus requiring a
form of UICC (traditional UICC or eUICC).
A supplier of the secure eUICC modules and resident software (such as
firmware and operating system). The hardware, software and production
processes are expected to be certified to meet a specified level of security.
This role may be performed by two entities – one of which delivers the
hardware and the other supplying the lifetime resident software. However,
even if the role is performed by a combination of entities, accreditation shall
be applied as if the eUICC is provided by a single entity.
The eUICC supplier provides the necessary credentials for managing the
eUICC to at least one SM.
4.1
No. Role
1 Device Vendor
2 eUICC supplier
3 Machine-to-A type of enterprise subscriber, which provides machine-to-machine
Machine Service services for business customers and consumers.
Provider (M2M
SP)
Mobile Network Provides communication services to their customers through wide area
Operator (MNO) wireless networks.
Where the SM role is not performed by the MNO, the MNO shall be
connected to at least one Subscription Manager.
4
5 (Trusted eUICC) An organisation trusted by MNOs to manage the active profile and other
Subscription profiles within the eUICC. The role of the SM minimises the changes for the
Manager (SM) subscription management for MNOs.
Several Subscription Managers may exist; an accredited process of eUICC
handover and associated credential exchange has to be established
between them.
The Subscription Manager role may be performed by any organisation that
meets the necessary standardisation requirements, including MNOs. The
necessary relationships between an SM and an MNO required for the SM
to perform its role are to be defined (see Ongoing Topics).
4.2
Trust Relationships
The following trust relationships are required.
No.
1
Description
It is essential that the party which performs the transition from the pre-initialised to the
initialised state (see Functional Use Case F1) is trusted by all MNOs and service providers
which ever use the eUICC to store credentials.
Associated obligations and liabilities in relation to fraud management must be agreed.
The current primary contractual and trust relationship between the UICC/SIM vendors and
any other 3rd parties that are involved in provisioning the UICCs/SIMs must remain between
these parties and the operator.
{Note1: Must end up with a model that maintains the obligations of SIM vendors to support
2
3
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No. Description
required security levels.}
{Note2: The Operator must be ultimately responsible for the security and proper functioning of
its network and the SIM plays a vital role in this. For this to happen, any players with a critical
role in the security of the SIM must be acting under both contractual and financial
responsibilities to the Operator. In addition to the safety and security arguments, the Operator
is the regulated entity, and the SIM plays a key role in allowing the operator to meet its
regulatory obligations.}
4 Evaluation and qualification protocols have to be executed by independent and agreed MNOs
qualified Laboratories.
4.3 eUICC Certification
The SIM/UICC is the security element chosen by mobile operators to ensure maximum
protection, based on a physical component hosting industrial secrets that cannot be
fraudulently modified. Currently the qualification of each element of the chain, as well as the
qualification of the whole, is undertaken by mobile operators and their business partners.
Any eUICC solution that will be agreed on will have to include and implement qualification
processes and criterion acknowledged by all actors, specifically MNOs providing industrial
secrets. Maintaining a formal certification for the overall eUICC (including USIM), as new
profiles (including applications) are downloaded, is theoretically possible. However, covering
the whole range of profiles would seem ambitious, and more than is required. However, with
only self-certification and commercial trust relationships there is a risk that assurance is not
robust enough. For example, a manufacturer claims compliance, and the Subscription
Manager only does business with manufacturers making such claims. However, no one has
confirmed the specification of the eUICC provided.
What is recommended is an approach that sits between self-certification (based on
recommended criteria) and formal certification:
A formally evaluated certification under a Protection Profile for the initial eUICC,
covering hardware, OS and secret keys management;
An SAS-like accreditation for the eUICC supplier, particularly covering its processes
for key management and initial provisioning;
An SAS-like accreditation for the Subscription Manager, particularly covering its
processes for key management and OTA provisioning.
The following trust relationships are then required.
Then the MNO only deals with accredited SMs; and the MNO has a contractual relationship
with the SM whereby an MNO's profile is only ever sent to certified eUICCs from accredited
eUICC suppliers. In addition, MNOs and SMs between them get the message across to
eUICC suppliers that, to succeed in the market, they have to have the eUICC certification
and manufacturer accreditation.
This should enable an informal security composition and with all the elements in place, the
end result should provide sufficient assurance for a secure ecosystem. An intended
outcome of this approach is that when a device is bought into a region from a different
“region” (e.g., country); additional re-certification should not be needed.
Currently, it is unclear which body should do the eUICC certification. In addition, a
Protection Profile will need to be defined (see Open Issues). The alternatives are:
Find an existing standard profile that fits the purpose; or
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The scheme is not about certification against standard profiles, but rather
certification against claimed profiles - and then we can define our own "minimum
claimed profile" without having to get it standardised.
None of the above shall preclude a formal security composition being achieved where
required, for example some financial NFC cases.
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5 Use Cases
A range of use cases is identified in this section to derive requirements for the development
of a trusted framework for the management of an embedded UICC (eUICC). This is not
intended to be an exhaustive list of use cases and applications, but a set of examples to
ensure requirements will be flexible enough to support securely both current and future use
cases.
The use cases are divided into vertical and functional use cases, where the vertical use
cases define usage scenarios and functional use cases define logical operations. Each
functional use case needs to be supported by at least one vertical.
Use cases are provided as a means to understand and add context to the overall
requirement.
5.1
5.1.1
Vertical Use Cases
Overview of the use cases
No. Use Case Description
UC1 Provisioning of A Machine-to-Machine Service Provider (M2M SP) sets-up M2M
multiple M2M subscriptions for a number of connected M2M devices to start
subscriptions. telecommunication services with a first MNO. Optionally, the M2M SP
may later change subscriptions to a subsequent MNO.
UC2 Provision of first A subscriber purchases a new type of communications or connected
subscription with device from a device vendor together with a subscription to provide first
a new services to this device.
connected
device
UC3 Subscription
Change
UC4 Stop
Subscription
UC5 Transfer
Subscription
A subscriber changes the subscription for a device to stop services with
the current MNO and start services with a new MNO in accordance with
policy control functions for each MNO.
A subscriber sells his device and stops the subscription for services from
the current MNO.
Subscriber transfers subscription between devices.
It should be noted that all Use Cases above are required to support M2M / embedded
service usage. UC1 explicitly describes a role for an M2M Service Provider.
5.1.2 UC1: Provisioning of multiple M2M subscriptions
A Machine-to-Machine Service Provider (M2M SP) sets-up M2M subscriptions for a number
of connected M2M devices to start telecommunication services with a first MNO. While it is
expected that there will be a very great range of M2M applications, and many of these will
have different parties and business models, it is likely that the key technical requirements
will become clear through examining a few examples of this use case; the following
examples are considered further in this section:
a) Provision of first subscription, and optional later change of subscription, for
communication services for automated reading of utility (electricity, water, gas)
meters; a M2M Service Provider will contract these subscriptions.
b) Provision of first subscription and optional later change of subscription for a security
camera.
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c) Provision of first subscription, and optional later change of subscription for
communication services to vehicles (e.g. telematics); the vehicle vendor will provide
the automotive services.
5.1.2.1 UC1a) Utility Meters
The Meter Reading M2M SP has a commercial contract to both supply meters and – once
they have been installed – to provide regular meter readings of these meters to the utility
company. The M2M SP selects the preferred MNO to provide a number of subscriptions
after completing a tender process for the communication services as part of a defined
service level agreement.
Once the MNO is selected, the M2M SP arranges for the utility meters to be installed, and
as part of the installation process for the communication services to start. While the physical
installation is a manual process, the subscription management required for the
communication services will be automated.
Contracts for communication services should be negotiated to last for a period of several
years; when / if a change of contract is negotiated, the change is likely to apply to multiple
subscriptions. The changeover is expected to be managed in an automatic fashion at an
agreed date over a relatively short period.
5.1.2.2 UC1b) Security Camera
A consumer purchases a security camera for monitoring his house. The security camera is
supplied with a subscription for communication services so that recorded data is uploaded
and stored as part of the service from a security (M2M) SP. The consumer (or M2M SP)
installs the camera and sets up access to the security services online.
The M2M SP selects the MNO for the video camera service; the subscription management
will be automated for the contracted number of subscriptions between the M2M SP and the
MNO.
Contracts for communication services should be negotiated to last for a period of several
years; when / if a change of contract is negotiated, the change is likely to apply to multiple
subscriptions. The changeover is expected to be managed in an automatic fashion at an
agreed date over a relatively short period. Noting that the level of MNO coverage within
individual properties can be different, an automated check of coverage for the target MNO
may form part of any subscription update.
5.1.2.3 UC1c).Telematics
A consumer purchases a new vehicle and this includes a number of vehicle manufacturer
provided services delivered over wide area wireless communications to the vehicle and its
occupants. The services will be delivered whether the vehicle is mobile or stationary, and
whether or not the vehicle is in the country in which it was purchased. The vehicle
manufacturer himself or a subcontractor acts as M2M SP, providing both vehicle related
services (such as engine monitoring) and being a broker for services supplied by other SPs
(such as infotainment).
The subscription will be activated at vehicle purchase to be operational as the customer
drives the vehicle away; the subscription management will be automated for the contracted
number of subscriptions between the M2M SP and the MNO. The M2M SP agrees to the
commercial contract with MNO(s) in either the same or different countries for subscriptions
for the communication services; the vehicle customer may not know which MNO is providing
communication services.
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Contracts for communication services should be negotiated to last for a period of several
years; when / if a change of contract is negotiated by the M2M SP, the change is likely to
apply to multiple subscriptions. The changeover is expected to be managed in an automatic
fashion at an agreed date over a relatively short period.
5.1.3 UC2: Provision of first subscription with a new connected device
An end user purchases a new type of communications or connected device from a device
vendor together with a subscription to provide first services to this device. While it is
expected that there will be a range of consumer purchased devices for communication,
media and Internet applications and more, and many of these will have different parties and
business models, it is likely that the key technical requirements will become clear through
examining a few examples; the following examples are considered further in this section:
a) Provision of a new device; the consumer will select the MNO to provide
communication services.
b) Provision of multiple connected new device for an enterprise workforce; the
enterprise will select the MNO to provide the subscriptions.
c) Purchase of a new device with the first subscription already pre-loaded.
5.1.3.1 UC2a) Provision of a new device
A consumer purchases a new device with a eUICC and then selects an MNO for
communication services. The MNO might be selected at the same or another retailer, with
an MNO shop or online and will be activated within a short period. First use of the new
device will be with the first subscription already set-up, or if no subscription is set-up, the
user will select an MNO and, if required, after appropriate authorization a subscription will
be set-up. Subscription set-up may happen via the mobile network using either a pre-loaded
first subscription or a provisioning subscription or via any other connectivity mechanism
provided by the device and the eUICC SM, subject to required end-to-end security being
LAN, WLAN, Bluetooth, or USB.
The subscription management will be automated for this single consumer subscription
between the consumer and the MNO. The consumer agrees to the contract with the MNO
for the subscription for the communication services.
5.1.3.2 UC2b) Provision of multiple devices for an enterprise
An enterprise (Purchasing Manager) purchases new devices for a set of employees.
Contracts for multiple subscriptions will be negotiated for communication services, which
enable a range of telecommunication and enterprise applications. The subscriptions will be
activated as new employees start, at the latest on their first use of the device. Subscription
activation may happen via the mobile network using a pre-loaded subscription or via any
other connectivity mechanism provided by the devices and the eUICC SM, subject to
required end-to-end security being LAN, WLAN, Bluetooth, or USB.
The subscription activation may be followed by device management to configure enterprise
specific applications and directories.
The subscription management will be automated for the contracted number of subscriptions
between the enterprise and the MNO. The enterprise agrees to the commercial contract
with MNO(s) for subscriptions for the communication services; the enterprise employees will
be aware of which MNO is providing communication services.
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5.1.3.3 UC2c) Purchase of device with subscription pre-loaded
A consumer purchases a new device with a eUICC with a pre-loaded subscription for
communication services from a specific MNO.
Subscription management is set up so that it is possible for the consumer to change the
subscription at a later point in time, for example at the end of a contract period in
accordance with the relevant policy control functions.
5.1.4 UC3: Change of subscription for a device
A subscriber changes the contract and thus subscription for the device to stop services with
the current MNO and start services with a new MNO.
a) Change of a subscription for a device by the consumer.
b) Change of the subscriptions of multiple connected new devices for an enterprise
workforce to a new MNO; the enterprise will select the MNO to provide the
subscriptions.
c) Change of the subscription by the consumer for a device, which had the first
subscription already pre-loaded. This is expected to be the same as UC3a therefore
is not considered further.
5.1.4.1 UC3a) Change of subscription by consumer
A contract for communication services of a device is expected to last for a period of one or
more years; when / if a change of contract is decided upon by the consumer, the change is
likely to apply to a single subscription, or possibly a few subscriptions the consumer has for
connected devices. The changeover is expected to be managed seamlessly in an automatic
fashion at an agreed date. The changeover shall be undertaken in accordance with relevant
Policy Control Functions as defined by the Donor Operator first and the Recipient Operator
second. In addition to new MNO subscription data, the change of subscription may involve
provisioning of a new eUICC network access application as well as MNO specific
applications, and the movement of consumer data stored within the eUICC. In parallel, there
may be management for telephone number portability.
5.1.4.2 UC3b) Change of subscriptions for devices for enterprise workforce
Contracts for communication services for the workforce are expected to be negotiated to
last for a period of one or more years. When / if a change of contract is negotiated by the
enterprise, the change is likely to apply to multiple subscriptions, and the changeover is
expected to be managed in an automatic fashion at an agreed date over a relatively short
period. The changeover shall be undertaken in accordance with relevant Policy Control
Functions as defined by the Donor Operator first and the Recipient Operator second. In
addition to new MNO subscription data, the change of subscription may involve provisioning
of new eUICC applications, and the movement of enterprise and individual employee data
stored within the eUICC. In parallel, there may be device management for enterprise
applications as well as the management of telephone number portability.
5.1.5 UC4: Termination of a subscription for a consumer device
A consumer sells his mobile device and stops usage of the services from the current MNO.
Note that some form of settlement between MNOs and consumers may be needed when
devices with upfront paid subscription fees change subscription before the end of the
contract period. It is expected that there will be a range of consumer purchased devices and
business models and it is likely that the key technical requirements will become clear
through examining a few examples.
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The following examples are considered in this section:
a) Removal of a subscription and related services from a device.
b) Termination of a device contract with an MNO.
c) Termination of a contract for multiple connected new devices for an enterprise
workforce where the enterprise selected the MNO.
d) Termination of the contract by the consumer for a device, which had the first
subscription already pre-loaded. This is expected to be the same as UC4b so is not
considered further.
e) Termination of service by MNO to prevent fraud or network damage. Device is not
allowed to connect to any MNO without some physical intervention. (Note in the
description we may have to have caveats about supporting emergency calls –
maybe national regulatory issues)
5.1.5.1 UC4a) Removal of a subscription from a device
A consumer wants to sell his device. Before selling the device, he wants to remove the
subscription and related services from the device while keeping the device contract with the
MNO.
To remove the subscription, the consumer leaves his device connected to the network or
reconnects, allowing the eUICC MNO to request the SM to send a command, the eUICC is
switched to the eUICC provisioned state.
The buyer can then set-up a new subscription in the same way as for a new device.
The subscription management will be automated for the removal of this single consumer
subscription between the consumer and the MNO.
5.1.5.2 UC4b) Termination of a device contract with an MNO
A consumer wants to sell his device. Before selling the device, he terminates the contract
with the MNO. This will trigger the removal of his subscription and related services from the
eUICC.
If the consumer leaves his device connected to the network or reconnects, allowing the
eUICC MNO to request the SM to send a command, the eUICC is switched to the eUICC
provisioned state.
If the consumer does not reconnect before selling his device, then the eUICC is switched to
the eUICC provisioned state possibly triggered as a result of a network error code or user
interaction.
The buyer can then set-up a new subscription in the same way as for a new device.
The subscription management will be automated for the removal of this single consumer
subscription between the consumer and the MNO.
5.1.5.3 UC4c) Termination for multiple connected enterprise devices
An enterprise wants to take multiple devices out of use and hand them over to employees
for private use or to a company that sells used company equipment. Before handing the
device to employees or another company, the enterprise will terminate the contract with the
MNO, and thus trigger the removal of the related subscriptions. The eUICCs are switched to
their provisioned state and any buyer can set-up a new subscription in the same way as for
a new consumer device.
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The subscription management will be automated for the removal of these enterprise
subscriptions between the enterprise and the MNO.
5.1.6 UC5: Subscriber transfers subscription between devices
A number of scenarios can arise where credentials are required to be moved from device A
to device B. Examples are listed below:
a) Due to Fault.
b) Customer requires change.
c) Move subscription from a eUICC to a traditional UICC or vice versa (need to be
consistent with definitions – applications etc).
5.1.6.1 UC5 a) Transfer due to Fault
Following identification of a fault on a previously supplied device, a second device is
supplied and the subscription and related services transferred from the original device to the
replacement device.
In addition to all the subscription parameters, also all the related eUICC services (e.g. NFC
applications etc.) may be removed from the device with a wipe command avoiding the
misuse of specific applications by third parties for fraudulent scope. The wipe command
shall be authenticated by the eUICC before being executed to prevent remote denial-of-service attack. As the customer will perform the subscription transfer, the pre-existing
activated services will be downloaded on the new eUICC.
As the original device cannot be assured to be operational, the subscription must be deleted
in the MNO systems (including HLR/AUC) and a new subscription has to be installed into
the eUICC of the replacement device.
This may imply a loss of data for the customer, unless a backup of the whole “package” is
secured somewhere at MNO (or SM) premises.
5.1.6.2 UC5 b) Transfer requested by Customer
A consumer transfers usage from one device that supports eUICC to another for some
reason. The user will want to transfer the subscription and related services from the device
while keeping the device contract with the MNO.
To remove the subscription, the consumer leaves his device connected to the network or
reconnects, allowing the eUICC SM to send a command, the eUICC is switched to the
eUICC provisioned state. The transfer shall be undertaken in accordance with relevant
Policy Control Functions as defined by the MNO.
For the replacement device, the subscription set-up may happen via the mobile network or
via any other connectivity mechanism provided by the device and the eUICC SM, subject to
required end-to-end security being LAN, WLAN, Bluetooth, or USB.
5.1.6.3 UC5 c) Transfer between eUICC and UICC
A consumer transfers usage from a device that supports eUICC to one where eUICC
support is not available for some reason. The user will want to transfer the subscription from
the device while keeping the device contract with the MNO.
To remove the subscription, the consumer leaves his device connected to the network or
reconnects, allowing the eUICC SM to send a command, the eUICC is switched to the
eUICC provisioned state.
The user and MNO can then use traditional methods to set-up a subscription for the
replacement device.
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The subscription management will be automated for the removal of this single consumer
subscription between the consumer and the MNO.
Note that in the opposite case “UICC to eUICC”, existing MNO policies and procedures
should apply.
5.2
Functional Use Cases
No.
F1
Use Case Description
Pre-Provisioning (within Takes various components, un-provisioned eUICC, Device,
a trusted environment) (optionally) Host Equipment and provisions the eUICC with the
necessary Initial Credentials to enable connection to a 3GPP
access network (or via any other connectivity mechanism
provided by the device and the eUICC SM, subject to required
end-to-end security being LAN, WLAN,
Bluetooth, or USB) for subsequent re-provisioning.
Post Sale (initial) Initially provisioned eUICC within a device or host equipment
Provisioning (outside a and module is updated with a selected MNO credentials.
trusted environment)
{Note 1: May (or may not) include MNO selection}
{Note 2: For the MNO this will be linked to network/billing/crm
activation and establishing a subscription}.
{Note 3: What happens when no user interface on the device?}
F2
F3 Life-cycle Management Enables remote re-configuring of the MNO credentials.
{Note 1: Care required to avoid scenarios that create, for
example, a signalling thrashing scenario within the network
without the ability to create an authenticated and authorised
connection in cases where volumes could be incredibly high.}
{Note 2: There would exist a need for a contractual
mechanism, to define the period whereby a eUICC can be
disabled.}
F4 Re-Provision Remove subscription associated with MNO A and replace with
subscription for MNO B.
Donor Operator and subscriber must give permission for a new
subscription. However, an existing subscription can be
removed without subscriber permission; typically, this would be
due to non-fulfilment of contractual obligations. At all times,
there shall be some credentials within the eUICC that permit
radio access.
F5 MNOs subscription swap An inactive subscription from MNO1 becomes active, while the
previous active subscription from MNO2 becomes inactive.
Policy control functions as defined in LIF9 / LIF10 / SM4 shall
be applied.
Device Transfer Transfer an existing subscription (including data/applications)
from one device to another within a single MNO.
{Note: Need to understand if there is a use case that requires
the transfer of other data/applications associated with the
subscriber identity, e.g. replicate experience of moving UICC
containing SIM+banking application from one device to another
device.}
F6
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6 Processes
Describes processes and how they relate to roles etc. the different processes phases are
given as examples to illustrate steps of processes that may be considered to resolve the
embedded requirements but do not mandate any particular added requirement; Therefore,
not all steps will need to be supported by the solution.
The requirement to minimise the changes for MNO subscription management processes
leads to the introduction of a new role: the Subscription Manager (SM). The introduction of
this role will minimise the number of interfaces required by an MNO to manage the
personalisation of a eUICC. The SM shall provide interfaces to the MNOs for subscription
data in the same manner as done by UICC manufacturers today. The SM shall enforce the
Policy Control Functions defined by each MNO the SM acts on behalf of, noting that an
MNO may manage the policy control function in its own right. The processes described
below takes the SM role into account.
Within the examples below the service providers (for example SP for metering, security or
vending machines) and the affected devices (for example utility meter, security camera..)
are different. However, the processes for the provisioning or changing of an M2M
subscription are the same. They are described below in a generalised way.
The processes below describe individual steps as being triggered by specific actors in the
system (e.g. being triggered by eUICC). The process steps do not imply that any technical
solution must follow these steps or use the actors in this way.
6.1
6.1.1
UC1: Processes for (multiple) M2M use cases
UC1 a) Provisioning an M2M subscription on a new device
an M2M SP has established a commercial contract for the provisioning of certain
devices
M2M SP has selected device vendor to supply devices with integrated modems
M2M SP has selected MNO to provide first communication services
Pre-conditions
Start
Process
of
the M2M SP requires new devices
The M2M SP requests the M2M device vendor to supply a batch of devices
The M2M device vendor requests the eUICC supplier to supply a batch of eUICCs
The eUICC supplier produces and provisions each eUICC with secret data
For each eUICC, the eUICC supplier sends secret data to the eUICC SM. This
secret data enables the eUICC SM to uniquely identify and authenticate the
eUICC
The eUICC supplier ships the eUICCs to the M2M device vendor, who integrates
them in the devices.
{Note: This may also be a multi-step integration process involving MNO or other
manufacturers, e.g. a modem manufacturer, who will integrate the eUICC into a
modem that is then integrated into the device. During or after the integration, the
M2M device vendor may wish to test device, possibly using either the provisioning
subscription or a pre-loaded MNO subscription to access a network.}
eUICC may optionally include MNO credentials
The M2M device vendor ships the devices to the M2M SP
At each device installation, the eUICC requests the device to set up a data bearer.
(Note: In the case that a mobile data bearer is used, this requires a provisioning
subscription to be present, e.g. with the eUICC SM acting as providing
connectivity through an appropriate agreement MVNO.) SM is responsible for
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whatever access is used for provisioning linked to above comments
The eUICC generates a request for a first subscription and forwards this request
via a data bearer to the eUICC SM
The eUICC SM looks up the M2M SP that is associated with the device. (Note:
The required mapping to M2M SP may have been provisioned with the eUICC
SM; or can be part of the request.)
The eUICC SM verifies the validity of the request with the M2M SP and requests
the identity of the MNO that will handle the subscription
The eUICC SM contacts the MNO to exchange the subscription information
including associated secret data
The eUICC SM sends updates to the eUICC to activate the MNO's subscription
The eUICC instructs the device to terminate the temporary data bearer that was
used for establishing the first subscription
The eUICC instructs the device to setup a data bearer to the eUICC SM using the
new subscription
The eUICC confirms to the eUICC SM that the new subscription has been
established
The eUICC SM confirms new subscription is active with the M2M SP
Post-conditions
a first subscription is established for the device
6.1.2 UC1 b) Process for changing a M2M subscription
The M2M SP requires activation of new subscriptions to already deployed
devices.
The M2M SP knows identities of the devices for subscription change, or, at least,
knows basic information for the eUICC SM to determine the identities.
The M2M SP has already negotiated commercial contracts for the provision of an
agreed number of subscriptions with the new MNO and agreed the termination of
existing contracts, and thus subscriptions, with the current MNO.
Start
Process
of
The M2M SP requests the eUICC SM to update subscriptions for a specified batch
of devices for the new MNO within an agreed time schedule. Note: The M2M SP
may also contact the current MNO or the new MNO to initiate the subscription
change, thereafter the MNO will forward the request to the eUICC SM.
The eUICC SM contacts the new MNO to exchange the subscription information
including associated secret data.
For each individual eUICC within the batch; the eUICC SM sets up a temporary
data bearer to the eUICC; this may be using the current MNO communication
services.
The eUICC SM sends updates to the eUICC to activate the new MNO's
subscription
The eUICC SM terminates the temporary data bearer that was used for changing
the subscription
The eUICC instructs the device to setup a data bearer to the eUICC SM using the
new subscription
The eUICC confirms to the eUICC SM that the new subscription has been
established
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For the batch of devices; the eUICC SM confirms old subscriptions terminated
with the previous MNO and new subscriptions active with the M2M SP
Post-conditions
the subscriptions are changed for the batch of devices
6.1.3 UC1 c) Process for fallback to a previous subscription
It is possible to provision a first subscription or change a subscription using a mobile
network. During this process there is a risk that the M2M device cannot connect to the new
network (e.g. due to lack of coverage). In order for the M2M device not to get lost, the
following process is initiated by the eUICC:
In the processes described above, if at the step where "The eUICC instructs the
device to setup a data bearer to the eUICC SM using the new subscription" setting
up of the data bearer fails, the process continues as follows:
o The eUICC retries to set up a data bearer for a number of times at defined
time intervals.
o If all retries fail, the eUICC re-activates the previous (operational)
subscription and notifies the eUICC SM that activation of the new
subscription has failed. Note 1: This requires the old subscription to be held
active in the network until a successful change is confirmed by the eUICC
SM. Note 2: Switchback could also happen to the provisioning subscription.
o Corrective actions are initiated by the eUICC SM.
6.2 UC2: Provision of first subscription with new device
A consumer purchases a new type of communications or connected device from a device
vendor that includes a subscription to provide first services to this device. While it is
expected that there will be a range of consumer purchased devices for communication,
media and Internet applications and more, and many of these will have different parties and
business models, it is likely that the key technical requirements will become clear through
examining a few examples; the following examples are considered further in this section:
a) Provision of a new device; the consumer will select MNO to provide communication
services.
b) Provision of multiple connected new devices for an enterprise workforce, and the
later change of the multiple subscriptions to a new MNO for communication services;
the enterprise will select the MNO to provide the subscriptions.
c) Purchase of a new device with the first subscription already pre-loaded.
While there are a number of similarities for many parts of the processes for the example use
cases, there are also sufficient differences such that a single general process to cover these
examples is not clear. The processes for each use case example are described below.
6.2.1 UC2 a) Provision of device consumer selects MNO
Retailer has agreed the commercial terms for the supply of new devices.
Retailer has selected device vendor to supply devices with eUICCs.
Start
Process
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The retailer requires a new batch of devices to sell.
The retailer requests the device vendor to supply a batch of devices.
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The device vendor requests the eUICC supplier to supply a batch of eUICCs.
The eUICC supplier produces and provisions each eUICC with secret data.
For each eUICC, the eUICC supplier sends secret data to the eUICC SM. This
secret data enables the eUICC SM to uniquely identify and authenticate the
eUICC.
The eUICC supplier ships the eUICCs to the device vendor, who integrates them
in the devices.
The device vendor ships the devices to the retailer.
A consumer purchases and takes delivery of a new device from the retailer –
either directly at a retailer shop or on delivery after an online purchase.
The consumer then selects and agrees a personal contract for an MNO
subscription; this may be in the shop where the device was purchased, another
shop or online.
At power-up of the new device, an application running on the device and / or the
eUICC, and / or a connected PC with Internet connectivity, initiates the
provisioning of a first subscription.
The eUICC requests the device to set up a data bearer. (Note: In the case that a
mobile data bearer is used, this requires a provisioning subscription to be
present.)
The eUICC generates a request for a first subscription, possibly including the
MNO and new subscription contract reference, and forwards this request via a
data bearer to the eUICC SM.
Via the MNO policy control, the eUICC SM verifies the validity of the request with
the consumer who purchased the device and if not already included, requests the
identity of the MNO and reference for the first subscription contract.
In accordance with the MNO policy control the eUICC SM confirms validity of
reference for a new subscription; if this is valid, the SM requests to exchange the
subscription information including associated secret data.
The eUICC SM sends updates to the eUICC to activate the MNO's subscription.
The eUICC instructs the device to terminate the temporary data bearer that was
used for establishing the first subscription.
The eUICC instructs the device to setup a mobile data bearer to the eUICC SM
using the first subscription.
The eUICC confirms to the eUICC SM that the first subscription has been
established.
The eUICC SM confirms the first subscription is active with the MNO and the
consumer who purchased the device and agreed the MNO contract.
Post-conditions
A consumer selected first subscription for communication services is established
for the purchased device.
6.2.2 UC2 b) Provision of enterprise devices
An Enterprise (Purchasing Manager) has agreed the contract to purchase
multiple new devices for new employees over a given period.
The Enterprise (Purchasing Manager) has selected, negotiated and agreed a
contract for communication services, which enable a range of
telecommunication and enterprise applications.
Pre-conditions
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The MNO or retailer that supplies the devices has sufficient numbers of the
selected model in stock. For each eUICC within these devices, the eUICC
supplier has sent the secret data to the eUICC SM.
Start of Process
The Enterprise orders a new batch of devices and communication services
for a group of new starters.
Enterprise orders and takes delivery of a batch of new devices from the MNO
or retailer.
Enterprise IT and Communications department activates the agreed MNO
subscription within the device, and provides this working device to the new
starter; alternatively, the IT and Communications department provides a
device and subscription set-up instructions to the new employee.
At power-up of the new device, an application running on the device and / or
the eUICC, and / or a connected PC with Internet connectivity, initiates the
provisioning of a first MNO subscription for the Enterprise.
The eUICC requests the device to set up a data bearer. (Note: In the case
that a mobile data bearer is used, this requires a provisioning subscription to
be present.)
The eUICC generates a request for a first subscription, possibly including the
MNO and the Enterprise new subscription contract reference, and forwards
this request via a data bearer to the eUICC SM.
Via the MNO policy control, the eUICC SM verifies the validity of the request
with the Enterprise that purchased the device and, if not already included,
requests the identity of the MNO and reference for the Enterprise first
subscription contract.
The eUICC SM contacts the MNO to confirm validity of reference for a new
subscription; if this is valid, eUICC SM requests to exchange the subscription
information including associated secret data.
The eUICC SM sends updates to the eUICC to activate the MNO's
subscription.
The eUICC instructs the device to terminate the temporary data bearer that
was used for establishing the first subscription.
The eUICC instructs the device to setup a mobile data bearer to the eUICC
SM using the first subscription.
The eUICC confirms to the eUICC SM that the first subscription has been
established.
The eUICC SM confirms the first subscription is active with the MNO and the
Enterprise.
The MNO may use device management to configure the device for the
contracted set of Enterprise services.
Post-conditions
The new employees in the Enterprise have devices with an active
subscription for communication services.
6.2.3 UC2 c) Device with first subscription pre-loaded
An MNO has decided to offer a pre-loaded subscription with a device
package.
The MNO has contractual agreement with a device vendor to supply
particular models of devices with eUICCs pre-configured with the first MNO
subscription.
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Start of Process
The MNO requires a new batch of devices to sell.
The MNO requests the device vendor to supply a batch of devices with pre-loaded MNO subscriptions.
The device vendor requests the eUICC supplier to supply a batch of eUICCs
with pre-loaded MNO subscriptions.
The eUICC supplier produces and provisions each eUICC with secret data.
For each eUICC, the eUICC supplier sends secret data to the eUICC SM.
This secret data enables the eUICC SM to uniquely identify and authenticate
the eUICC. The eUICC supplier also requests the first subscription data to be
pre-loaded from the eUICC SM.
The eUICC SM contacts the MNO to confirm validity of a reference for a new
batch of first subscriptions; if this is valid, eUICC SM requests the MNO to
provide the subscription information including associated secret data to the
eUICC supplier. (Note: this may be via the eUICC SM which is a trusted
entity.)
The eUICC supplier ships the pre-loaded eUICCs to the device vendor, who
integrates them in the devices.
The device vendor ships the devices to the MNO.
A consumer purchases and takes delivery of a new device from the MNO –
either directly at an MNO shop or on delivery after an online purchase from
the MNO. This device already has an active MNO first subscription and is
ready for use.
Post-conditions
The first subscription for communication services is active for the device the
consumer purchased.
6.3 UC3: Change of Subscription for a Consumer Device
A consumer, enterprise or retailer / device vendor changes the contract and thus
subscription for the device to stop services with the current MNO and start services with a
new MNO.
a) Change of a subscription for a device by the consumer.
b) Change of the subscriptions of multiple connected new devices for an enterprise
workforce to a new MNO; the enterprise will select the MNO to provide the
subscriptions.
c) Change of the subscription by the consumer for a device, which had the first
subscription already pre-loaded.
UC3b will follow the same general process as described for the change of multiple M2M
subscriptions in section 6.1.2, with the only change that the Enterprise will request the
change of subscriptions instead of an M2M SP. For the remaining use cases, the consumer
initiated change follows the same general process as follows.
Pre-conditions
The consumer is using a connected device with a eUICC and a subscription for
telecommunication services. Where the subscription is part of a bundled service,
< with a tablet PC, it is assumed that the consumer seeks the new MNOsubscription directly from the new MNO.
The consumer seeks to change the MNO subscription with an existing connected
device.
Start of
Process
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The consumer selects and agrees a commercial contract for the provision of a
subscription with the new MNO in a shop or online, and agrees the termination of
existing contracts with the current MNO (or retailer).
The consumer requests the new MNO to update the subscription for a specified
device. In accordance with policy control functions, the MNO requests the eUICC
SM to update the subscription for this specified device.
The eUICC SM exchanges the subscription information including associated
secret data with the new MNO.
The eUICC SM sets up a temporary data bearer to the eUICC; this may be using
the current MNO communication services.
The eUICC SM sends updates to the eUICC to activate the new MNO's
subscription.
The eUICC SM terminates the temporary data bearer that was used for changing
the subscription.
The eUICC instructs the device to setup a data bearer to the eUICC SM using the
new subscription.
The eUICC confirms to the eUICC SM that the new subscription has been
established.
The eUICC SM confirms that the old subscription is terminated with the previous
MNO, that the new subscription is active with the new MNO and that relevant
policy control has been applied.
Post-conditions
The subscription is changed for the consumer device.
6.4 UC4: Termination of a Subscription for a Consumer Device
A consumer sells his mobile device and stops the contract for services from the current
MNO. Note that some form of settlement between MNOs (or retailers if they manage the
subscription) and consumers may be needed when devices with upfront paid subscription
fees change subscription before the end of the contract period. While it is expected that
there will be a range of consumer purchased devices and business models, it is likely that
the key technical requirements will become clear through examining the following few
examples:
a) Removal of a subscription, services and sensible data from a device.
b) Termination of a device contract with an MNO.
c) Termination of a contract for multiple connected new devices for an enterprise
workforce where the enterprise selected the MNO.
d) Termination of the contract by the consumer for a device, which had the first
subscription already pre-loaded.
The above consumer and enterprise use cases follow the same general process as follows.
Pre-conditions
Start
Process
The consumer or enterprise end user is using a connected device with a eUICC
and a subscription for telecommunication services.
of
The consumer or enterprise seeks to remove the subscription and optionally
terminate the MNO contract for an existing connected device, or batch of devices.
The consumer or enterprise agrees any commercial implications for the
termination of the contract(s) with the MNO if known, or with provider of the
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connected device (retailer) if the contract is bundled.
The consumer or enterprise requests the current provider of the subscription to
remove the subscription. The subscription provider contacts the MNO to advise of
the removal of the subscription (if not the MNO itself).
The provider of the subscription contacts the eUICC SM to remove the
subscription for a specified device or batch of devices.
The eUICC SM sends an update to the eUICC to remove the current MNO's
subscription and the eUICC switches to provisioned state. In the case, that the
contract is terminated, the next time the device connects, the eUICC is switched to
the eUICC provisioned state possibly triggered as a result of a network error code
or user interaction.
The eUICC confirms to the eUICC SM that the subscription has been removed.
The eUICC SM confirms that the old subscription is removed with the MNO, and if
different, the provider of subscriptions who confirms the removal and optionally
termination with the consumer or enterprise.
Post-conditions
The subscription is removed from the specified consumer device(s).
6.5 UC5: Subscriber transfers subscription between devices
A number of scenarios can arise where credentials are required to be moved from device A
to device B. Examples are listed below:
a) Due to Fault.
b) Customer requires change.
c) Move subscription from a eUICC to a traditional UICC or vice versa (need to be
consistent with definitions – applications etc).
No specific process flows have been created for these use cases.
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7 Requirements
The following requirements are provisionally categorised into groups for ease of reading.
These groups are only suggested and should not be considered as final categorisation.
Importantly, all Requirements tables should be considered when deriving any solutions to
these requirements.
7.1
No.
LIF1
LIF2
LIF3
LIF4
LIF5
LIF6
LIF7
LIF8
LIF9
Lifecycle requirements table
Requirement
There shall be a mechanism to install a provisioning subscription onto the eUICC.
There shall be a mechanism to install a first subscription onto the eUICC pre-issuance.
There shall be a mechanism to install a first subscription onto the eUICC post-issuance.
There shall be a mechanism to change the current installed profile from one MNO to
another MNO.
It shall be possible to configure the eUICC that it needs to seek the first subscription on
power-up.
It shall be possible to load profile data and applications in the same session or in a different
session as for the loading of the subscription.
It shall be possible to securely delete the MNO subscription and data including credentials,
profile and applications, without assigning a new MNO subscription identity.
Provisioning and re-provisioning should be possible without removing the UICC or the
device from its operating environment during the lifetime of the device
Provide for more than one „profile‟ within a eUICC at any stage in its lifecycle but only permit
a single profile to be active at any point in time. Any action on the active profile shall be
subject to validation, which shall include among other considerations, reference to the
Policy Control Functions (PCF) of the MNO that owns the active profile on the eUICC. The
PCF may be undertaken by the MNO or the SM acting on its behalf.
{Note that an active profile may contain multiple applications if desired.}
LIF10
The provisioning of multiple profiles on a eUICC shall be subject to control of individual
MNOs administered through policy control functions. (E.g., an MNO should have the ability
to declare whether it permits a eUICC to hold its credentials alongside those of other MNOs
when its credentials are not active, or in the case where it is the active MNO, whether other
credentials can be stored.)
The provisioning of the eUICC (whatever this is in detail) shall be triggered by the
subscriber or by (personnel of) the recipient operator. Where there is a donor operator then
the provisioning shall be done in accordance with policy control functions of the donor
operator, followed by the policy control functions of the recipient operator.
It shall be possible a) transfer subscription to another device, or b) delete the subscription or
c) store the subscription in a secure way to reuse it later; a „profile‟ cannot be active in more
than one device in any case.
Policy control functions may impose specific requirements on the process of subscription
change to ensure that it is genuinely under subscriber control. For example, where the
subscriber is a human end user of the device, the policy may require that change requests
are initiated through the UI, that the device reboots after any such change and the change
is clearly visible through the UI.
A device no longer containing a valid operational profile may be assigned new profiles and
MNO credentials.
Personalisation may include identities, keys, algorithms, and applications. Not all
personalisation may be performed at the same time, and there will remain a split whereby
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LIF11
LIF12
LIF13
LIF14
LIF15
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No. Requirement
some or all personalisation will continue to be undertaken prior to the eUICC leaving the
vendor environment, or combination of the vendor and Subscription Manager entities.
LIF16
The eUICC should be able to be de-activated (e.g. locked and its memory wiped clean).
{Note 1: An example of the use of this facility is when a device is stolen. Such an event
would also be expected to cause an update in the GSMA IMEI database.}
LIF17
LIF18
It shall be possible for the Device Vendor to test the device before shipment using the
provisioning subscription or pre-loaded MNO subscription.
There shall be a clear specification of which credentials can be changed at which lifecycle
state of the eUICC and the associated security with these changes. (E.g. Algorithm can be
loaded into the eSIM at the personalisation of the eSIM at the factory, crypto libraries
cannot be changed as built into the )
The eUICC must contain a minimum set of credentials to allow the device/eUICC to attach
to a network and be updated with an Operator‟s data, irrespective of the type of network it is
allowed to connect to.
LIF19
7.2
No.
SM1
Service Management Requirements Table
Requirement
There shall be a mechanism of provisioning an operational profile onto the eUICC in a
secure way.
{Note: depending upon device characteristics, market, and other considerations the
mechanism for installing an operational profile may vary and cover „wired‟ and „wireless‟
(and other) connectivity.}
SM2
SM3
SM4
SM5
SM6
These requirements shall support the management of any type of NAA subscription, e.g.
SIM, USIM, CSIM, and R-UIM
It shall be possible to manage MNO specific profiles and applications on the eUICC in
accordance with LIF9 and LIF10.
Solution should allow for remote provisioning (and de-provisioning) of additional eUICC
based services during lifetime of subscription and device.
Bulk re-provisioning should be supported where under the control of a single subscriber.
{Note: to enable bulk switching for M2M scenarios}
Before changing MNO credentials on a eUICC a check needs to be performed that the new
profile will fit on the destination eUICC.
{Note: appropriate checks required to ensure that this is transparent and doesn‟t introduce
unfair practises blocking transfer}
SM7
The donor operator shall be able to provide SIM usage guarantees to the recipient operator
before activation of provisioning phase; this may include lifetime counters, additional
counters…
The donor operator and/or the corresponding SM shall be able to provide to recipient
operator sufficient information level before activation of provisioning phase; such
information may include memory space available, hosted algorithms, OTA capabilities
The mobile network operator retains the ability and the right to update elements of its
profile, e.g. setting configurations or adding new applications, without needing user
intervention or consent.
{Note: see note in SM1}
SM8
SM9
SM10
V1.0
There may be application mechanism on the eUICC that identifies a change of device.
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No.
SM11
Requirement
It shall be possible for the consumer data stored on the eUICC to be transferred during the
change of the current subscription from one MNO specific profile to another MNO specific
profile.
In the same way as traditional UICCs, the eUICC shall continue to allow MNOs to deploy
custom / proprietary applications using for example SIM Toolkit applications.
Memory availability for MNO profiles on the eUICC shall not be restricted beyond that
necessary to provide the eUICC capability.
SM12
SM13
7.3
No.
COM1
COM2
Communications Requirements Table
Requirement
All remote provisioning shall employ secure standardised communications mechanisms.
The provisioning mechanism shall also be able to run over other connectivity mechanisms:
Internet (fixed or wireless), local connectivity (e.g. Bluetooth), NFC using the security
mechanism specified for COM1. Subject to equivalent end-to-end security being provided.
7.4
No.
ROB1
ROB2
Robustness Requirements Table
Requirement
The mechanism to install a subscription in a secure way should be allowed for the life-time
of the eUICC.
Mechanisms shall exist that safeguard against mis-application of provisioning changes on
the eUICC that result in erroneous states or devices being unintentionally left without
connectivity.
{Note: the specific cases and procedures when fallback would be applied need to be
defined.}
ROB3
ROB4
The use of safeguard mechanisms shall be set at the time a eUICC provisioned state is to
be changed.
The SM shall be available 24 x 7 with extremely high reliability.
7.5
No.
L1
L2
L3
L4
L5
L6
Liability Requirements Table
Requirement
The eUICC shall be specified, tested and approved by the operators approved body.
{Note: Specification to include features to cover protection from attack etc.}
SIM profile shall be specified, tested and approved by the operator.
It must be possible to accredit the manufacture and provisioning of any solution in a
similar manner to the current SAS provided by GSMA
The provider of the subscriptions shall be the operator or a trusted party on behalf of the
operator
The SM shall notify MNOs of changes to status of their subscriptions in a device.
Transfer of secure data (e.g. Ki and authentication algorithm) must be over agreed
mechanisms which meet agreed common security requirements and where suitable trust
relationships are in place.
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No.
L7
Requirement
{Note: ETSI and Global Platform have prior work in this area that can be re-used.}
After migration between MNO A to MNO B, each operator shall receive a proof of the
subscription migration procedure execution; this proof shall be compatible with each legal
courts able to represent each operator;
In case this proof has not being received, the SIM shall be able to come back to the
previous MNO A
7.6
No.
MAR1
MAR2
MAR3
Market Requirements table
Requirement
The eUICC shall comply with all standardised form factors, as per Ref 1.
Any compliant solution to these requirements shall be able to be multi-sourced for
competition and business continuity.
If licensing is required for a solution to these requirements, any such licence must be
granted on a FRAND basis.
{Note: Ideally, solutions shall not require licensing and FRAND is seen as a maximum and
not a necessity.}
MAR4
MAR5
MAR6
MAR7
MAR8
MAR9
MAR10
Any element of a solution to these requirements that needs to be used across or between
ecosystem players shall be standardized and open.
A compliant solution to these requirements should be commercially deployable in short
timescales; guideline is 18 months from publication of this document.
As far as possible, the solution should be based on existing standards for deploying
(U)SIMs on UICCs - as per References to this document.
As many as possible existing logistics, interfaces and processes should be retained in any
solution to these requirements.
The use of a eUICC must not mandate the need for any change in existing personalisation
and distribution models.
The solution should enable device manufacturing without pre-determination of either the
operator network, or the geographic location where the device shall be used.
Any MNO shall be able to choose from a range of trusted parties to provision a SIM profile
to any given eUICC, rather than operators being “locked in” and forced to use the original
supplier of the eUICC hardware.
{Note: Several Subscription Managers may exist, and then an accredited process of
eUICC handover and associated credential exchange has to be established between them
(§4.1.5).}
MAR11
MAR12
The solution has to support all existing business processes and provide the flexibility to
enable new ones
The entire MNO profile, including any eUICC authentication algorithms and associated
data, remain the property of the mobile network operator, even when provisioned into a
eUICC hardware device not supplied by the operator.
There needs to be a cross-industry agreement on the base specification (or specifications)
for a eUICC (e.g. memory size, OS, APIs, which standards realise compliance).
Any solution to these requirements must be compatible with MNO strategies for third party
services: GSMA PBM, GSMA digital signature and identity, NFC services.
The solution must not preclude an MNO to play the role of the Subscription Manager.
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MAR13
MAR14
MAR15
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7.7
No.
SEC1
SEC2
SEC3
SEC4
SEC5
SEC6
SEC7
SEC8
SEC9
SEC10
SEC11
Security requirements table
Requirement
The eUICC shall have a unique, constant and secure hardware identity.
The hardware identity in SEC1 shall be in a secure way remotely accessible, for example
to correlate the eUICC with a specific customer.
Any process for loading credentials to the eUICC shall ensure that the plain text form of
those credentials is only available within the destination eUICC.
It shall be possible for the eUICC to provide an additional level of confidentiality between
the MNO and the eUICC for subscription and secret data.
Overall security shall be at least equivalent to that achieved with current removable UICC
implementations, processes and OTA management.
Current levels of resistance to Fraud within Provisioning processes must not be reduced.
The SIM application must be at least as resilient to attack as current SIM application
solutions.
The embedded UICC arising from these requirements and any applications that reside
upon it as part of a solution must also be as resilient to attack as current solutions.
End to end protection needs to be provided when personalisation data is sent between
trusted entities and where un-trusted entities form part of the data transmission.
All data transmitted towards the eUICC under these requirements shall be integrity
protected.
It should be possible to upgrade the security of the SIM remotely (for example against new
attacks on the authentication algorithm and if possible against new side-channel attacks).
{Note: this is a desirable and not mandatory as currently written. Also, this requirement
should be subject to eUICC capability.}
SEC12
SEC13
SEC14
Private data of an operator shall never be disclosed to another operator without his
agreement.
Any solution to these requirements shall define conditions in which security conditions
data can or cannot be updated
Under no circumstances shall a device be allowed to use a mobile channel (for
provisioning) unless the device is authenticated for mobile access. In particular,
provisioning may only take place over a mobile channel if there is already a credential in
place allowing authentication to an MNO so that the device can use that mobile channel.
eUICC provisioning shall be done in such a way that a provisioning message created for
one eUICC cannot be misused to provision or modify any other eUICC; nor can it be
recorded and later misused to modify the target eUICC a second time. Cryptographic
means may be used to achieve these requirements.
Authentication of a eUICC and SM shall be mutual in both directions.
Any MNO or SM should be able and allowed to check that the new remote candidate
eUICC is compatible with their minimum secure, operational and functional requirements.
This check may be performed remotely in a secure way.
{Note: The results of such a check are likely to form a part of policy control decisions.}
SEC15
SEC16
SEC17
SEC18
Any solution to these requirements shall be no more vulnerable to large scale denial of
service attacks than current provisioning systems
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7.8
No.
CERT1
CERT2
CERT3
Certification Requirements Table
Requirement
Certification to include a formally evaluated certification under an agreed Protection Profile
for the eUICC.
Certification to include an SAS-like accreditation for the eUICC manufacturer, covering, at
least, its processes for key management and initial provisioning.
Certification to include an SAS-like accreditation for the Subscription Manager, covering,
at least, its processes for key management and OTA provisioning.
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8 Ongoing Topics
To enable Embedded SIM to reach the market, the GSMA intend to continue their work on a number
of areas connected with the introduction of Embedded SIM, especially on topics where
„standardisation‟ bodies are not typically active / involved or where it is too soon to undertake work in
a standards body. A non-exhaustive list of such topics is provided below. This work will be conducted
as part of a GSMA project and within the appropriate GSMA Working Groups.
No.
1
Issue Description
eUICC Ownership Introduction of the eUICC within M2M and Embedded Devices is likely to
introduce changes to UICC ownership from the current solution of being
MNO owned. The consequences of changes and how they are
addressed need to be resolved.
eUICC
Certification
Currently, it is unclear which body should do the eUICC certification. In
addition, a Protection Profile will need to be defined. See section 4.3
eUICC Certification.
2
3
Trust and Liability The necessary relationships between SMs and MNOs.
Models / Role of
the SM
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9
9.1
Document Management
Document History
Date
28 Nov 2010
10 Jan 2011
14 Jan 2011
17 Jan 2011
2 Feb 2011
4 Feb 2011
21 Feb 2011
Version
0
0.61
0.62
0.63
0.7
0.8
1.0
Brief Description of Change
Initial version
Update incorporating comments provided
on version 0.6.
Post meeting version for final Task Force
review prior to sending to GSMA EMC,
SG, SC.
Final version for EMC, SG review
Final Draft Version
For SC Approval
SC Approved
Approval
Authority
Editor /
Company
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
Ian Pannell
/ GSMA
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omissions, please contact us with your comments. You may notify us at prd@
Your comments or suggestions & questions are always welcome.
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