The enquiries revealed that while it is true that subscriptions to mobile telephony services require the presentation of an identification document and an official proof of address, the situation is different when it comes to the application for a top-up SIM card. The internal rules of the service providers include a requirement for EU and EEA citizens to be in possession of a valid photo ID to buy a top-up SIM card.

In the cases investigated, this information was not passed on to the customer service staff, so that the regulated practice could not be enforced in the shops. The service providers did not find any errors or deficiencies during the investigation of the problem that would indicate a systemic problem, and all service providers concluded that the incident reported to them could have been the result of an individual error or a series of errors by the administrator.

In order to ensure that their practices are fully compliant, service providers have taken effective steps to enforce their rules in accordance with the legislation by sending information notes to their customer service staff, by including follow-up questions on the problem in their knowledge checks and by providing training in their knowledge update training programmes.