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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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GSM Association

Embedded SIM Task Force: Requirements & Use Cases

Non-Confidential White paper

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

appropriate standards necessary that will permit remote provisioning and remote re-V1.0 Page 3 of 38

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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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Embedded SIM Task Force: Requirements & Use Cases

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 MNO

subscription 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

It is our intention to provide a quality product for your use. If you find any errors or

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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