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Aftab Maken
ISLAMABAD: The Pakistan Telecommunication Authority (PTA) has imposed a fine of Rs 77,800,000 (Rupees seventy-seven million eight hundred thousand) on China Mobile Pakistan Limited (CMPak), which operates under the brand name Zong, after finding the company in breach of the mandatory 100-metre geo-fencing requirement governing Biometric Verification System (BVS) devices used for SIM sales.
The enforcement order, issued under Section 23 of the Pakistan Telecommunication (Re-organization) Act, 1996, was signed on August 6, 2026, by the PTA’s three-member hearing panel comprising Chairman Maj. Gen. Hafeez ur Rehman (R), Member (Compliance and Enforcement) Dr. Khawar Siddique Khokhar, and Member (Finance) Muhammad Naveed.
How the Violation Was Detected
According to the order, the case originated from a field inspection carried out by the PTA on March 30, 2026. During the survey, regulatory officials found that Mr. Malik Abbas Gohar Rehman, a sales representative affiliated with CMPak’s Taxila franchise (CFTXL00001), was conducting SIM sales at I-10 Markaz, Islamabad — well outside the franchise’s approved territorial jurisdiction and designated geo-location.
The Authority subsequently directed the operator, via email dated April 1, 2026, to investigate the matter and explain the violation. CMPak confirmed on April 7, 2026, that it had already initiated disciplinary proceedings against the franchise by issuing it a show-cause notice.
Formal enforcement proceedings began on April 28, 2026, when PTA issued a show-cause notice requiring CMPak to submit a compliance report within five days and a written explanation within thirty days as to why an enforcement order should not be passed against it.
The Regulatory Framework at Stake
Under Clause 5(r) of the Standard Operating Procedure (SOP) on SIM Sale and Activation through Biometric Verification — dated April 2, 2019 and amended on August 5, 2025 — every BVS device is required to remain within 100 metres of the geo-location of its approved sales channel. No SIM sale is permitted beyond that boundary unless specifically authorised by PTA, and any relocation of a device requires prior approval from the Authority. The SOP separately requires prior PTA approval before any door-to-door or kiosk sale activity can be undertaken.
The order also invoked Regulation 4(4) of the Subscribers Antecedents Verification Regulations, 2015, which places sole responsibility for every SIM sold — regardless of the channel — squarely on the licensed operator, along with License Conditions 3.1 and 6.7.11, which bind operators to comply with all directions and SOPs issued by PTA.
CMPak’s Defence
In its response, CMPak did not dispute that the sale had taken place outside the designated geo-location. Instead, the company argued that the episode was an isolated lapse by a single Data Sales Officer (DSO) rather than a systemic compliance failure. It maintained that every SIM involved had been activated only after successful biometric verification, that records remained fully traceable, and that there had been no biometric bypass, fake SIM issuance or failure of NADRA verification.
The operator told the Authority it had acted swiftly once notified — issuing a show-cause notice and warning letter to the franchise, terminating the DSO responsible, circulating compliance advisories across its sales network, and placing the sales channel under enhanced monitoring. Legal counsel for CMPak, including Barrister Raja Ammar Jilani, appeared before the panel at a hearing held on July 8, 2026, and reiterated that the franchise operated on a principal-to-principal basis, arguing the DSO’s conduct could not be attributed to the licensee and that no monetary penalty was warranted given the corrective steps already taken.
PTA Rejects the Defence
The Authority was unconvinced. In its findings, PTA held that biometric verification and geo-fencing are two independent regulatory obligations serving distinct purposes — one confirms subscriber identity, the other confines sales activity to authorised locations, curbs unauthorised movement of BVS devices, and reduces the risk of untraceable SIM issuance. Compliance with one, the order states, cannot substitute for compliance with the other.
The panel also dismissed the argument that responsibility could be shifted to the franchise or an individual employee, noting that the statutory and licence-based obligation to ensure lawful SIM sale rests directly and non-delegably with the operator. On the question of corrective measures, PTA acknowledged them as a mitigating factor relevant to the quantum of penalty, but held that remedial action taken only after a violation is detected does not erase the contravention itself — a principle the Authority said was essential to preserving the deterrent effect of the regulatory framework.
PTA concluded that CMPak had failed to exercise effective supervision over its authorised sales channel and held the company liable under Section 23 of the Act, directing it to deposit the fine within ten days of receiving the order, failing which further legal action would follow.
Part of a Wider Enforcement Drive
This penalty adds to a broader crackdown PTA has mounted against Pakistan’s cellular operators over SIM-issuance compliance in recent months. Just weeks earlier, on July 15, 2026, the regulator had fined all four major mobile operators a combined Rs740 million for violations including unauthorised SIM activations and biometric-verification lapses — with Zong/CMPak alone penalised Rs155.6 million in that round, alongside Rs116.7 million fines each for Jazz (PTML) and Telenor Pakistan, and over Rs233.4 million for Ufone. Local technology outlets, including ProPakistani and TechJuice, covered that action extensively, framing it as part of PTA’s intensified push against illegal SIM sales and identity fraud following a string of citizen complaints about SIMs being activated against their CNICs without consent.
Coverage of the latest CMPak order was picked up quickly by Pakistani business and technology media, including Business Recorder, TechJuice and Bloom Pakistan, all of which highlighted PTA’s central finding that successful biometric verification cannot “cure” a separate breach of the geo-fencing rule — a distinction likely to be closely watched by other operators given its implications for how franchise and DSO-level lapses are treated under the compliance regime.
On social media, PTA’s enforcement actions against telecom operators — including recurring complaints about unauthorised SIM activations and unconsented service charges — have continued to draw public criticism, with users routinely tagging both the operators and the regulator’s official accounts to demand stricter oversight and faster consumer redress. Industry watchers say the latest fine is likely to reinforce PTA’s broader messaging that operators, not franchises or individual sales staff, bear ultimate responsibility for SIM-sale compliance nationwide.
