Quick Summary
Cross-border IoT relies on roaming but faces permanent roaming regulations that can block devices. Multi‑IMSI eSIMs localise connectivity by switching to local profiles, ensuring compliance, reducing costs and improving resilience. Success depends on managed orchestration, regulatory handling and platform-level control, not standards alone.
Cross-border and international IoT initiatives rely on seamless connectivity for roaming devices, typically involving multiple mobile operators. This can introduce regulatory challenges, including permanent roaming, where devices spend extended periods on foreign networks.
Permanent roaming represents a significant hurdle for international IoT and M2M deployments. Cellular networks were originally designed for consumer devices that only spend short periods of time as guests on foreign networks. But as IoT devices have extended their battery life and applications have matured, these devices spend more and more time roaming.
Roaming typically becomes ‘permanent’ when a device remains on a foreign network for longer than 90–120 days, depending on the region.
The permanent roaming challenge
While the permanent roaming model supports international connectivity for IoT and M2M devices, it can be restrictive, as different countries implement their own regulations to protect national interests.
For instance, the Brazilian regulator ANATEL has banned permanent roaming altogether, requiring IoT devices to register on local networks or face being blocked after 90 days.
These restrictions can create challenges for cross-border applications, such as supply chains, where hardware may reside in an importing country for its entire lifecycle, forcing enterprises to manage multiple contracts with multiple operators.
Beyond time limits, enterprises may also face obligations regarding cellular device registration, such as IMEI registration with local authorities, which may involve associated taxes or fees. Failure to comply with these local rules could lead to devices being disconnected with little or no notice, putting entire business models at risk.
What is a multi-IMSI SIM?
One potential solution to the permanent roaming challenge is to use Multi-IMSI (International Mobile Subscriber Identity) SIMs, which allows a single SIM card or chip to store and switch between different mobile network identities.
Unlike traditional SIMs tied to a single operator, a multi-IMSI SIM can hold a bootstrap profile for initial connectivity and multiple additional local network profiles for different operators around the world.
This capability is often delivered via eUICC (eSIM) form factors, and enables a device to dynamically switch to the strongest or most cost-effective network available in a specific region. For roaming devices this can ensure seamless operation across different regions without the need for a physical SIM swap.
How does a multi-IMSI approach solve the roaming problem?
A multi-IMSI approach solves the permanent roaming problem for IoT devices through a process known as federated localization (or eSIM localization). Instead of a device permanently roaming on a visited network, the multi-IMSI SIM uses intelligent eSIM cycling to switch to a local network profile. To the local network, the device appears as a local subscriber rather than a roamer, thereby bypassing permanent roaming bans and ensuring regulatory compliance.
This approach offers several strategic advantages:
Cost optimization: Roaming data rates can be prohibitively expensive and multi-IMSI SIMs optimize operational expenses by selecting the most cost-effective local network available.
Improved resilience: Devices can automatically switch to alternative networks if the primary connection fails, maintaining higher uptime.
Single SKU: Enterprises can build or buy one version of an IoT device with a single global eSIM that localizes upon arrival in the destination country, maintaining economies of scale and ease of management.
Understanding multi-IMSI and eUICC SIM
Technology has evolved from plastic SIM cards to eUICC and multi-IMSI solutions:
The SIM hardware (eSIM/eUICC/iSIM): An eSIM is the physical secure element that can be soldered or integrated directly into a modem chipset (iSIM).
The software (IMSI and Profiles): Multi-IMSI technology allows a single SIM to store and switch between multiple network identities and profiles.
The profile structure: eSIMs typically feature a bootstrap profile for initial connectivity on start-up and have localization profiles that can be downloaded Over-the-Air (OTA) to provide local network credentials once a device reaches its destination or goes into roaming mode.
Considerations for permanent roaming solutions
It may sound simple, but deploying a multi-IMSI solution is not as simple as flipping a switch, and requires significant technical and regulatory orchestration. As eSIM provisioning becomes more common, rules are emerging around personal data privacy, national data sovereignty, and security. For example, some regions require that data in transit never leave the country, necessitating local network profiles that comply with data sovereignty laws.
Key considerations include:
Operational complexity: The actual process of managing and switching eSIM profiles for hundreds or thousands of devices is incredibly complex, involving back-end integrations like SM-DP+ (Data Preparation) and SM-SR (Secure Routing) systems.
Regulatory compliance: Many countries require Know Your Customer (KYC) registration for every SIM, a regulatory process the connectivity provider must facilitate to prevent devices from being orphaned.
Connectivity Management Platforms (CMP): To handle this opportunity at scale, enterprises typically require a CMP to provide an interface for managing multiple contracts, billing reconciliations, and remote troubleshooting across different carriers.
SGP.32 standard: Although the arrival of the SGP.32 standard is a strategic enabler for massive IoT, the technology alone doesn’t achieve anything and its value is best unlocked when delivered as a managed service that abstracts the underlying technical complexity.
Advanced orchestration for resilient IoT
In summary, solving the permanent roaming problem is less about the "click of a button" solution promised by SGP.32 as a technology, and more about a fully managed service that abstracts 100% of the operational and regulatory complexity behind a single contract and platform.
Enterprises should consider using an eSIM orchestrator for a unified, simple approach to cross-border and international IoT deployments, to manage profile lifecycle, network selection, compliance, and unified billing.
Eseye’s Infinity platform embodies this role, providing a single pane of glass for orchestration, analytics, and control across global deployments. But while SGP.32 defines how profiles are delivered, resilience is not built into the specification alone. Uptime, network fallback behaviour, multi-network continuity and operational guardrails remain critical to success in real-world IoT environments.
Read more about Eseye’s SGP.32 eSIM orchestration here
Eseye brings decades of end-to-end expertise to integrate and optimise IoT connectivity delivering near 100% uptime. From idea to implementation and beyond, we deliver lasting value from IoT. Nobody does IoT better.
