# USA eSIM: The FCC SIM Rule Protects You, Not the Seller

Source: https://esimrules.com/destinations/united-states/
Author: Nadezhda Semenova — Entrepreneur, co-founder of the travel service Trippy (https://esimrules.com/about/)
Updated: 2026-09-12

> A USA eSIM: Change and Change+ run $3.99-$58.99 on T-Mobile, Verizon and U.S. Cellular, no ID required at checkout. FCC text read in full 16 August 2026.

## Does this apply to you? (there is a SIM rule — and it is on your side)

eSIM USA is Change and Change+, T-Mobile, Verizon and U.S. Cellular profiles sold to a traveler rather than assigned to a US subscriber’s account, and 47 Code of Federal Regulations (CFR) § 64.2010(h)'s SIM-swap rule binds the carrier holding that account, never the buyer at checkout. A federal rule about SIM changes exists in US telecom law, and it binds the carrier, not the traveler buying a plan.

47 CFR § 64.2010(h), read in full on 16 August 2026, tells a wireless provider how to authenticate a customer before swapping a SIM. That duty is owed to you as an existing subscriber. It is not a checkpoint you clear before you can buy one.

That duty is real, but paragraph (h) delays its own enforcement: § 64.2010(h)(9) suspends compliance until the paragraph gets a compliance date. The rule sits inside Subpart U of Part 64, which covers Customer Proprietary Network Information (CPNI). It binds “a provider of commercial mobile radio service (CMRS)... including resellers of wireless service.” The obligation falls on the carrier and any reseller selling under it. It does not fall on the person on the other side of the transaction.

This page reads one federal source: the Federal Communications Commission (FCC)'s own text of 47 CFR § 64.2010, Subpart U, 31,667 characters, saved and checked on 16 August 2026. What follows describes what the FCC’s own rules say, not the full field of US law that could touch a SIM — the gaps are named later, in “What we did not read.”

The product behind this page is the eSIM for the USA sold here: Change, data-only, and Change+, which adds voice minutes and SMS. Both run on T-Mobile, Verizon and U.S. Cellular with 5G, covered in full further down.

## What the FCC actually requires before a SIM can be changed

§ 64.2010(a) already binds every US carrier:

> “Telecommunications carriers must properly authenticate a customer prior to disclosing CPNI based on customer-initiated telephone contact, online account access, or an in-store visit.”

That duty is in force today. It covers a request for account data. § 64.2010(h) extends the same authentication standard to SIM changes by name. But the paragraph suspends its own enforcement. Paragraph (h)(9) reads:

> “Compliance. This paragraph (h) contains information-collection and/or recordkeeping requirements. Compliance with this paragraph (h) will not be required until this paragraph is removed or contains a compliance date.”

No compliance date exists as of 16 August 2026. Paragraph (h) is adopted and codified. Compliance with it, specifically, is on hold. § 64.2010(a), the general duty, carries no such hold. It applies today.

§ 64.2010(h) itself states:

> “A provider of commercial mobile radio service (CMRS), as defined in 47 CFR 20.3, including resellers of wireless service, shall only effectuate SIM change requests in accordance with this section. For purposes of this section, SIM means a physical or virtual card associated with a device that stores unique information that can be identified to a specific mobile network.”

Paragraph (h)(1) sets the standard the rule would apply once compliance starts:

> “A CMRS provider shall use secure methods to authenticate a customer that are reasonably designed to confirm the customer’s identity before executing a SIM change request, except to the extent otherwise required by 47 U.S.C. 345 (Safe Connections Act of 2022) or subpart II of this part. Authentication methods shall not rely on readily available biographical information, account information, recent payment information, or call detail information unless otherwise permitted under 47 U.S.C. 345 or subpart II of this part. ...”

Two carve-outs sit inside that text: 47 U.S.C. 345 and Subpart II of Part 64. Neither was read for this page; see “What we did not read,” below.

The practical bar the standard sets: a carrier could not confirm identity with a date of birth, a billing address, or a last payment amount. That information sits inside the “readily available biographical” and “account information” categories the rule excludes. Paragraph (h)(7) adds staff training on “fraudulent SIM change attempts.”

None of this reaches the moment you buy a prepaid eSIM. It reaches the moment an existing subscriber’s SIM gets swapped, when an attacker talks a carrier employee into moving someone’s number onto a SIM the attacker controls.

Two markers sit at the top of § 64.2010 in the eCFR text: links to “an amendment published at 88 FR 85814, Dec. 8, 2023” and “a correction published at 88 FR 88261, Dec. 21, 2023.” Neither is the full record. The section’s own authority line names five entries:

> \[82 FR 44419, Sept. 21, 2017, as amended at 88 FR 85814, Dec. 8, 2023; 88 FR 84448, Dec. 5, 2023; 88 FR 88261, Dec. 21, 2023; 89 FR 47870, June 4, 2024\]

88 Federal Register (FR) 84448, missing from the two markers, created Subpart II.

## US law counts an eSIM as a SIM. UK law does not

§ 64.2010(h) defines SIM as:

> “a physical or virtual card associated with a device that stores unique information that can be identified to a specific mobile network”

The virtual card, an eSIM, sits on equal footing with the physical one.

The UK’s Crime and Policing Act 2026 defines the same word differently, in a section that is not yet in force. Sections 151 through 153 received Royal Assent on 29 April 2026. They wait on a commencement regulation under section 255(1); none has been made as of 15 August 2026. Section 153(3) reads:

> “(a) a removable physical subscriber identity module, or (b) an article specified in regulations made by the Secretary of State.”

Branch (a) is a plastic card, physical and removable. Branch (b) is a power the Secretary of State has not yet used. Section 153(7) defines the word that power turns on: “Article” includes information in electronic form. An eSIM is information in electronic form. Branch (a) does not reach it today. Branch (b) is built so that it could, once a minister chooses to use it.

Two English-language jurisdictions treat the same word differently, in the same stretch of law. That comparison is possible only because both texts were read in full: the FCC’s rule on 16 August 2026, and [the UK](/destinations/united-kingdom/) Act’s sections 151-153, covered separately on this project. One condition applies. The two rules regulate different things. § 64.2010(h) authenticates an existing subscriber before a carrier moves their service to a new SIM. That is a fraud-prevention rule aimed at SIM-swap. Section 153 of the UK Act criminalizes possessing a SIM farm, a device running five or more SIM cards at once for bulk calling or messaging. That is a rule aimed at fraud infrastructure, not at individual subscribers. The definitions differ because the rules were written for different jobs, not because one country recognizes eSIM in general and the other does not.

That distinction still matters for your US eSIM specifically. § 64.2010(h) treats your eSIM as a SIM in full. Once the compliance hold on (h) lifts, its protection covers a virtual profile and a plastic card alike.

## No purchase-time ID rule — and the two places identity does appear

The FCC’s wireless rules hold no requirement to identify a customer at the point of buying a prepaid SIM. Six phrases were checked across Title 47, filtered to `hierarchy[title]=47`, checked 16 August 2026:

| Phrase searched | eCFR index rows (sections) |
|---|---|
| "register the subscriber" | 0 |
| "subscriber registration" | 0 |
| "proof of identity" | 0 |
| "prepaid subscriber" | 0 |
| "identity of the subscriber" | 5 rows |
| "subscriber identity module" | 4 rows |

*Method: eCFR returns one row per section revision, not one per occurrence in the text. A row count and a section count differ.*

The first four rows would carry a purchase-time rule if one existed. None does.

Five rows for “identity of the subscriber” resolve to two sections. § 54.404 contributes one row. It runs the National Lifeline Accountability Database. That is the federal subsidy program for low-income phone and internet service. It verifies identity for a subsidy, not for a SIM purchase. § 64.1120 contributes the other four, one per historical revision of the same sentence, current since 16 August 2018. It is the FCC’s rule against “slamming,” an unauthorized carrier switch. It confirms a change was actually requested by the subscriber. Neither section screens a new customer at checkout.

Four rows for “subscriber identity module” also resolve to two sections. Three belong to § 64.2010, covered above. The fourth belongs to § 64.6402, inside Subpart II of Part 64, added by 88 FR 84448 on 5 December 2023. That is the same Subpart II § 64.2010(h)(1) names as a carve-out, unread for this page (see the next section). § 64.6402 verifies a survivor’s identity. The survivor is separating a line from a shared mobile contract tied to domestic violence, human trafficking, or a related crime. It protects someone leaving a shared plan. It does not check someone buying a SIM.

The honest statement stays narrow. The FCC’s wireless rules carry no requirement to identify a SIM purchaser. That is not the same as claiming no identity check exists anywhere in US law tied to a SIM. Identity checks appear in Title 47 for three separate reasons. A subsidy database is one. Protection from an unauthorized carrier switch is another. Protection for a survivor separating a line is the third. None of them sit at purchase. Fifty states' law was never checked.

## What we did not read

Seven categories of US law and regulatory process sit outside what this page checked. Each could still carry a rule the FCC’s wireless regulations do not, or could change how the compliance hold above plays out.

The Communications Act of 1934 itself, 47 U.S.C., was not read. The FCC’s rules in Subpart U implement it, but the statute is a separate document; this page tried uscode.house.gov and law.cornell.edu on 16 August 2026, and neither responded.

Subpart II of Part 64 was not read either. It is the carve-out § 64.2010(h)(1) names, and home to § 64.6402, the fourth “subscriber identity module” row from the section above. This page has read only the quoted carve-out language, not the subpart itself.

The four Federal Register documents behind § 64.2010’s 2023-2024 amendments were not opened individually: 88 FR 85814, 88 FR 84448, 88 FR 88261, and 89 FR 47870. This page read only the codified result they produced. Whether OMB has approved paragraph (h) as an information-collection requirement, the step that would trigger the compliance date in (h)(9), was not checked.

State law was not checked. Fifty states each run their own consumer-protection and telecom statutes, and none were read for this page.

Carrier terms of service — T-Mobile, Verizon, U.S. Cellular, any reseller — were not read. Whatever a carrier requires at sale, beyond federal rules, is a commercial term, not law, and this page does not know what it says.

Device import and certification rules were not checked. The FCC runs those through its equipment-authorization program, FCC ID. That is a different question from subscriber identity, and this page did not read it.

Border checks were not read either. Whatever the CBP or TSA asks when you enter the US sits outside FCC telecom rules.

None of this changes the count in the section above. It answers one specific question: does the FCC’s wireless regulation require identifying a SIM purchaser? It does not answer the broader question of everything US law, state and federal, could require.

## What you get: Change and Change+ on T-Mobile, Verizon and U.S. Cellular

The eSIM for the USA sold on this site comes in two products. Change is data-only. Change+ adds voice minutes and text messages on top of data. A claim that “the eSIM doesn’t make calls” applies to some travel eSIMs, but not to Change+.

Both run on T-Mobile, Verizon and U.S. Cellular with 5G, KYC not required at checkout (Airalo catalog data, checked 16 August 2026). The install window runs 365 days from purchase, the usage clock starts at first connection, and both products recharge with no expiry.

| Plan | Price |
|---|---|

The 5 gigabytes (GB) / 30-day Change plan is the one most three-to-four-week US trips land on.

## The APN you have to type on Android: wbdata

Android does not fill in the Access Point Name (APN) for Change or Change+ automatically. Typing it in yourself is a required step, not an optional one. iOS fills it in on its own. Once the profile installs and shows as active, open the network settings for that SIM. Find the Access Point Name field and enter `wbdata` exactly. Save it, and data should connect within a minute or two.

The USA is one of 73 countries in [Airalo’s catalog](https://www.airalo.com/united-states-esim) where Android needs this typed in by hand (121 of 368 entries, 32.9%, checked 3 September 2026) — worth ruling out first if a freshly installed profile shows no internet. Eight of the nine dedicated US eSIM pages checked for this site never mention an APN. The ninth mentions one in passing: a Turkish troubleshooting line, with no value to type. `wbdata` appears zero times across all nine. Checked 16 August 2026 across four domains: mobimatter.com, simbye.com, saily.com and roafly.com.

This step has nothing to do with the SIM-authentication rule covered above. § 64.2010(h) governs how a carrier verifies you before changing a SIM already in service. APN configuration is a one-time setup step on a new profile, handled entirely on the device, with no carrier interaction at all.

## Before you fly, and on landing

Install the profile before departure, on Wi-Fi, not at the arrivals gate. The QR code or install link needs a working connection, and signal on landing is not guaranteed. The 365-day install window means buying weeks ahead costs nothing.

Nothing activates at install. A profile shown as installed but inactive before boarding is normal — the clock starts at first connection, once you land and turn on data roaming.

Running the US eSIM alongside a home SIM works on any dual-SIM phone: set it as the data line, and turn off cellular data on the home SIM only, so nothing pulls a roaming charge by accident.

If this is your first eSIM install, the US eSIM works the same way as anywhere else once the APN step above is done on Android. [The iPhone install guide](/guides/install-esim-iphone/) and [the Android install guide](/guides/install-esim-android/) cover the QR-scan and manual-entry paths in full. For a dated look at Airalo’s own track record across destinations, see [the Airalo review](/reviews/airalo/).

## FAQ

## Sources and freshness

This page reads 47 CFR § 64.2010, Subpart U of Part 64 of the FCC’s rules, sourced from eCFR at ecfr.gov, saved locally as a 31,667-character file and read in full on 16 August 2026. Every provision cited above — (a), (h), (h)(1), (h)(7), (h)(9) — comes directly from that text. The section’s authority line credits five Federal Register documents, none opened individually. See “What the FCC actually requires,” above.

The same six phrase searches ran through eCFR’s own full-text search API, filtered to `hierarchy[title]=47`, checked 16 August 2026. eCFR returns one row per section revision, not one per occurrence in the text. The two non-zero rows are accounted for at § 54.404, § 64.1120 and § 64.6402.

The UK comparison above cites sections 153(3) and 153(7) of the Crime and Policing Act 2026, read from this project’s saved copy of sections 151 through 153 and 254 through 255, 13,325 characters. Those sections received Royal Assent but are not yet in force, per section 255(1).

Seven categories of US law and process were not read for this page. Each is named above, in “What we did not read.”

Plans, pricing, network coverage, KYC status, and the install and top-up windows for this eSIM for the USA come from Airalo’s own catalog data for Change and Change+, checked 16 August 2026. Airalo can change any of it without notice.

This page reads FCC regulation as of 16 August 2026, including the compliance hold on paragraph (h) stated in (h)(9). It does not predict future rulemaking, and it should be rechecked before relying on it for anything beyond ordinary travel use.

> *Sources cited only — expert review pending. For individualized advice, consult a licensed professional.*

## FAQ

Do I need to register my SIM or show ID to use an eSIM in the USA?
Not under the FCC's wireless rules. A phrase search across Title 47 for "register the subscriber," "subscriber registration," "proof of identity" and "prepaid subscriber" returns zero hits each, checked 16 August 2026. That covers the FCC's telecom regulations, not state law or a carrier's own terms; see "What we did not read," above.

What does § 64.2010(h) actually require?
§ 64.2010(h) sets an authentication standard for SIM changes, but paragraph (h)(9) delays its own enforcement: compliance "will not be required until this paragraph is removed or contains a compliance date," and no such date exists yet. The general duty in § 64.2010(a) carries no such delay and applies now. Either way, the duty falls on the carrier and its resellers, not on you as a buyer.

Does an eSIM count as a SIM under US law?
Yes. § 64.2010(h) defines SIM as "a physical or virtual card associated with a device that stores unique information that can be identified to a specific mobile network." The virtual card is named directly, with no separate treatment.

Is that the same in the UK?
No, and the UK section is not even in force yet. Section 153(3) of the Crime and Policing Act 2026 defines "SIM card" as "(a) a removable physical subscriber identity module, or (b) an article specified in regulations made by the Secretary of State," and section 153(7) adds that "article" includes "information in electronic form." Branch (a) misses an eSIM; branch (b) could reach it, but no regulation under (b) exists as of 15 August 2026, and sections 151-153 themselves wait on a commencement order under section 255(1). The two rules regulate different things anyway: the US rule protects an existing subscriber from SIM-swap fraud, and the UK rule targets SIM-farm possession.

Does Change+ include phone calls and texting?
Yes. Every Change+ plan bundles voice minutes and SMS messages with data, from 10 minutes and 10 texts on the smallest 3-day plan up to 500 minutes and 500 texts on the largest. Change, the data-only product, does not.

Why does my Android phone show no internet right after installing the eSIM?
Almost always a missing APN. iOS fills it in automatically; Android does not. Open the network settings for the profile and enter `wbdata` into the Access Point Name field manually. This single step accounts for most "no internet" reports on a freshly installed profile.