By Musa Abubarkar
_A customer dispute highlights a growing regulatory challenge as mobile numbers increasingly function as digital identities, banking credentials and gateways to financial services._
By any measure, mobile phones have become central to modern banking. In Nigeria, millions of customers use their mobile numbers to receive transaction alerts, authorise transfers, access USSD banking services, reset passwords and verify their identities across multiple financial platforms. The same numbers can eventually be disconnected, recycled and reassigned to entirely different individuals.
That reality is at the centre of a dispute involving Access Bank customer Rita Markenny Egba, who has publicly alleged that approximately ₦3 million was withdrawn from her account through USSD transactions between October and December 2025 while she was residing in Dubai. According to the account she has presented publicly, the mobile number linked to her bank account had allegedly been reassigned by her telecommunications provider to another subscriber before the disputed transactions occurred.
The case remains under investigation, and no determination has been made regarding liability. However, it raises a broader question that extends far beyond a single customer, one bank or one telecom operator:
Have telecommunications regulations kept pace with the reality that mobile numbers now serve as financial identities rather than merely communication tools?
*A System Built for Voice Calls, Now Used for Banking*
Nigeria’s telecommunications framework was developed at a time when mobile numbers primarily existed to facilitate calls and text messages. Under that model, number recycling is both normal and necessary. Telephone numbers are finite resources, and regulators and operators must ensure their efficient use.
The challenge is that the digital economy has transformed the function of a mobile number.
Today, a single mobile number may be connected simultaneously to bank accounts, mobile banking applications, USSD profiles, pension accounts, government databases, social media accounts, e-commerce platforms, National Identity Number records, and personal and business communications. A number that once served only as a means of contact has effectively become an identity token.
Yet many of the systems that rely on that identity token operate independently of one another.
*The Information Gap Nobody Owns*
One of the most striking aspects of SIM recycling is the apparent absence of a universal mechanism for informing every interested party when ownership of a number changes.
A telecom operator generally knows when a number becomes inactive. The telecom operator knows when the line is disconnected. The telecom operator knows when it is reassigned. The new subscriber undergoes some form of registration and identity verification.
However, a critical question arises: who informs the institutions that still regard the old owner as the legitimate user of that number?
Banks may continue to associate the number with the previous account holder. Digital platforms may continue sending one-time passwords. Online services may continue offering password recovery through the same number. Fraud prevention systems may continue treating possession of the number as evidence of identity.
The result is that a recycled number can sit at the intersection of two completely different identities.
*Why Telecom Records Matter*
In disputes involving recycled numbers, investigators often focus first on the financial transactions themselves.
Equally important, however, is the lifecycle of the telephone number.
Determining how events unfolded requires answers to questions that only the telecom operator can definitively address. Investigators will need to establish exactly when the line became inactive, what inactivity rules applied at the time, when the number was disconnected, whether the previous subscriber was notified, when the number was reassigned, who became the new subscriber, what identification documents were used during registration, and what records exist showing the chain of ownership.
These questions do not imply wrongdoing by the operator. Rather, they reflect the operator’s unique position as the custodian of the numbering resource.
Without reliable records, it becomes difficult to establish whether the number transition was handled properly and whether safeguards were adequate.
*The Emerging Regulatory Challenge*
The telecom industry faces a difficult reality.
On one hand, recycling numbers is operationally necessary. Mobile numbers are not unlimited. Regulators around the world allow reassignment after specified periods of inactivity.
On the other hand, every recycled number now carries potential digital baggage.
A disconnected line may still be associated with banking profiles, loan applications, investment accounts, ride-hailing services, email recovery systems, health records and business communications. In other words, reassignment today carries risks that did not exist when number-recycling policies were originally conceived.
The industry’s challenge is no longer simply managing numbering resources. It is managing identity risk.
*Could Better Cross-Sector Coordination Prevent Fraud?*
Many experts argue that the greatest weakness lies not in recycling itself but in the lack of communication between sectors.
Telecom operators know ownership has changed. Banks generally do not. Fintech companies may not. Government agencies often do not. Consumers may not realise a dormant number has been reassigned until long after it happens.
This creates an environment in which security controls designed around mobile-number verification can become vulnerable.
The issue is particularly significant in Nigeria because USSD banking remains widely used and mobile numbers continue to play a central role in customer authentication.
Whether such vulnerabilities contributed to the disputed transactions in the Egba case is a matter for investigators rather than speculation. Nevertheless, the case highlights risks that regulators have increasingly acknowledged in recent years.
*Shared Responsibility, Not a Single Point of Failure*
Public discussion following financial fraud incidents often centres on identifying one responsible party. The reality is usually more complex.
*Telecom Operators*
Operators manage subscriber lifecycles and possess the records relating to deactivation, churn and reassignment.
Their procedures, notifications, KYC processes and audit trails are therefore critical to understanding how any number transition occurred and whether regulatory requirements were followed.
*Financial Institutions*
Banks determine how accounts are authenticated and secured. They decide how transaction alerts are delivered, what controls govern USSD access and how suspicious activity is detected and escalated. They also determine what additional verification measures may be required when risk indicators emerge.
*Customers*
Consumers also play an important role. Customers are generally responsible for maintaining updated contact information and ensuring that banking credentials remain current, particularly when changing numbers or allowing lines to become inactive for extended periods.
*Regulators*
The NCC and the Central Bank of Nigeria regulate different parts of the ecosystem. Fraud linked to recycled numbers sits squarely between those regulatory domains, making cooperation essential. Effective consumer protection increasingly depends on coordinated oversight rather than isolated regulatory action.
*A Consumer Protection Issue Hiding in Plain Sight*
The growing concern around recycled numbers reflects a broader transformation in digital society.
Consumers increasingly think of a mobile number as something personal and permanent.
Telecommunications systems do not.
From a network perspective, a dormant number may eventually become available for reuse. From a consumer’s perspective, that same number may remain inseparable from years of financial, professional and personal history.
The tension between those two perspectives is at the heart of emerging SIM-recycling risks.
*Reforming the System Before the Next Case*
Regardless of how the Egba dispute is ultimately resolved, industry observers point to several reforms that could improve consumer protection.
Subscribers should receive multiple notifications before deactivation and potential reassignment, using alternative contact channels where available. Banks and regulated financial institutions should receive notification when ownership of a number changes, particularly where the number is used for authentication or transaction alerts.
There is also growing support for a centralised recycled-number registry that would allow authorised institutions to verify whether a number has recently been reassigned. Such a system could help banks, fintech companies and government agencies identify higher-risk numbers before relying on them for identity verification.
Another proposal is the introduction of cooling-off periods during which newly reassigned numbers would face restrictions before being used for sensitive financial activities. This would reduce the possibility of immediate exploitation where a number remains linked to a former subscriber’s accounts.
Telecom operators could further strengthen audit-trail requirements by maintaining detailed records showing every stage of a number’s lifecycle, from activation through deactivation, quarantine and reassignment. At the same time, consumer-awareness campaigns could educate customers about the risks associated with dormant numbers and the importance of updating banking and digital-service records whenever a number changes.
*Beyond One Customer*
The allegations raised by Rita Markenny Egba may ultimately be resolved through investigations, regulatory reviews or legal proceedings. The evidence may support some claims and challenge others. Those outcomes remain to be determined.
What is already clear, however, is that the dispute shines a light on a vulnerability affecting the entire digital ecosystem.
As mobile numbers become the keys to financial services, identity verification and digital trust, the question facing regulators is no longer whether numbers can be recycled.
It is whether the safeguards surrounding that recycling are strong enough for an economy in which a telephone number may be worth far more than the handset it rings on.
Musa Abubarkar is a former senior staff of a telecommunications company
