Activation of CUG Line No Longer Requires Personal NIN – What You Need to Know

Introduction

Closed User Group (CUG) services provide an effective means for specific groups and organizations to communicate seamlessly within their network. However, the Policy requiring National Identification Number (NIN) to be linked to sim cards in April 2022, brought a new layer of complexity as telecom operators insisted on linking CUG lines to individual NINs and employees were hesitant to share their personal NINs due to the sensitive nature of this information, and concerns about privacy, data security, and the management of NIN-linked CUG lines when employees left organizations. This made it cumbersome for organizations to effectively run and manage their CUG lines.

These uncertainties surrounding the implementation of the CUG lines in this era of NIN prompted the Nigerian Communications Commission (NCC) to introduce specific conditions for the provision of Closed User Group (CUG) services in the Nigerian telecom industry. In this article, we’ll delve into the essential conditions outlined by the NCC’s publication titled ‘CONDITIONS FOR OFFERING CLOSED USER GROUP (CUG) SERVICES IN THE NIGERIAN TELECOM INDUSTRY’. The conditions are set to take effect from November 1, 2023.

Eligible Entities

CUG services may now be offered to a variety of entities, including Large Corporate Organizations, Government bodies, Not-For-Profit Organizations, Duly Registered Residential Estate Associations, Trade Associations, and Micro Small and Medium Enterprises (MSMEs).

Number of Subscribers

For each eligible entity, there are specific subscriber requirements. The minimum number of Mobile Station International Subscriber Directory Numbers (MSISDNs) or subscribers for CUG activation is three. The maximum allowable subscribers vary from 200 – 30,000 depending on the entity as follows: 200 for MSME; 2,000 for Resident Estates Associations; 10,000 for Not-for-Profit Organizations (NGO); 20,000 for Government Agencies; 30,000 for Large Corporate Organizations; and 2,000 for Trade Associations.

Steps to registering your CUG

If your organization meets the eligibility criteria, the registration process involves two key steps:

1. Pay an access fee ranging between N400 and N5,000.
2. Submit the following mandatory documents:

For Large Corporate Organizations, Not-for-Profit Organizations, and MSMEs:

• Business Registration Document (Certificate of Incorporation, Certificate of Registration, or Certificate of Incorporated Trustees)
• Provision of Tax Identification Number (TIN)
• Signed contract agreement between the organization and the Mobile Network Operator (MNO)
• Proof of Identification of members within the given CUG
• The National Identification Number (NIN) of two company representatives

For Trade Associations and Resident Estates Associations:

• Business Registration Document (Certificate of Incorporation or Certificate of Incorporated Trustees)
• Provision of Tax Identification Number (TIN)
• Signed contract agreement between the organization and the MNO
• Proof of Identification of members within the given CUG
• The NIN of two company representatives
• The request for the service signed by two Trustees or Members of the Association’s Executive Committee (EXCO) on the letterhead
• Each subscriber shall provide a valid means of identification. A list of staff IDs on a signed letter may suffice in place of an ID card.

For Government Agencies (Federal, State, and Local):

• Signed contract agreement between the organization and the MNO
• Proof of Identification of members within the given CUG
• A list of staff IDs on a signed letter may suffice in place of an ID card
• The NIN of two company representatives; either Board members or Trustees
• A request for the service signed by two representatives; either C-Level Director, CEO or Board member on the letterhead of the Organization

Notably, the NIN requirement has been simplified, as the NINs of two company representatives are sufficient for registration, eliminating the need to link individual NINs to CUG lines.

Relationship Management

Telecom operators are advised to manage the relationship with the entities being offered CUG services by liaising directly with a designated staff of the organization. In cases where a third party/agent is engaged to manage the CUG relationship, the agent must be duly registered by the regulatory commission and hold a Class License.

Reports

Telcom operators are expected to submit a quarterly report to the Commission detailing newly registered CUG, subscribers added to an existing CUG and subscribers that left an existing CUG.

Conclusion

These conditions for offering Closed User Group (CUG) services in the Nigerian telecom industry aim to ensure fairness, accessibility, and transparency in the provision of these services. Adhering to these guidelines benefits both service providers and the entities seeking CUG services, promoting efficient communication and collaboration within specific groups and organizations.

We love to hear from you. Share your thoughts on these new conditions as issued by the NCC in the comment section.

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