与基于传统SIM卡的截获相比，eSIM的合法截获面临着独特的技术挑战。从实体SIM卡向嵌入式SIM（eSIM）技术的过渡正在重塑移动通信领域。 在GSMA远程SIM卡配置（RSP）架构的推动下，eSIM使用户无需物理更换SIM卡，即可切换运营商、激活配置文件并管理多个订阅服务。对消费者而言，这意味着更大的灵活性和便利性。对于运营商——尤其是负责 合法截取合规性 — eSIM 带来了新的复杂性，必须加以理解和解决。.
本文探讨了RSP架构对合法截获的影响，指出了eSIM在目标识别和截获管理方面带来的具体挑战，并为希望在支持eSIM的环境中保持合规性的运营商提供了实用指导。.
eSIM 合法截取的工作原理
The GSMA RSP architecture defines the ecosystem for managing eSIM profiles. The key components include the Subscription Manager — Data Preparation (SM-DP+), which prepares and securely delivers operator profiles to eSIM devices; the Subscription Manager — Discovery Server (SM-DS), which facilitates the discovery of available profiles; the eUICC (embedded Universal Integrated Circuit Card), which is the secure element within the device that hosts one or more operator profiles; and the Local Profile Assistant (LPA), which is the software on the device that manages profile download, installation, and switching. For IoT devices, GSMA SGP.31/SGP.32 replaces the user-driven LPA with a remote eSIM IoT Manager (eIM).
Under the RSP model, an operator’s profile — containing the IMSI, authentication credentials, network access configuration, and other parameters — is downloaded and installed onto the eUICC remotely. Multiple profiles can coexist on a single eUICC. Older eUICCs allow only one enabled profile at a time; since GSMA SGP.22 v3, devices supporting Multiple Enabled Profiles (MEP) can run two at once. Subscribers can switch between profiles — and effectively between operators — through a software operation on the device, without any physical intervention.
This dynamic, software-driven provisioning model is fundamentally different from the traditional physical SIM model, where the IMSI is personalised onto a card that has to be physically delivered. The implications for lawful interception are significant.
目标识别面临的挑战
合法截获令通常通过一个或多个标识符来确定目标：MSISDN（电话号码）、IMSI（用户标识）、IMEI（设备标识）或IP地址。eSIM模式以不同方式增加了上述每种识别方法的复杂性。.
MSISDN-based targeting is affected by the ease with which subscribers can change operators — and by extension change their MSISDN — through a simple profile switch. A target who suspects surveillance may switch to a different profile and MSISDN without a physical SIM changing hands. Similar switches have always been possible with dual-SIM phones. Each new profile still means a new subscription (in Germany, prepaid profiles require an identity check before activation, § 172(2) TKG), and its download is logged against the device’s EID. The operator that was performing the interception may lose visibility of the target entirely if the target activates a profile from a different operator.
基于IMSI的定位同样面临类似的挑战。eUICC上的每个运营商配置文件都有其专属的IMSI。当目标切换配置文件时，另一个IMSI会变得活跃，而原始的IMSI在网络上将不再可见。基于原始IMSI进行拦截的运营商会发现，目标似乎从网络上消失了。.
IMEI-based targeting is more stable in the eSIM context, as the IMEI is associated with the device rather than the SIM profile. Note that dual-SIM and multi-profile devices carry a separate IMEI for each simultaneously active subscription, and that the network usually learns the IMEI only at registration. However, IMEI-based interception has its own limitations — it may capture communications from other users who share the device, and it does not help if the target uses multiple devices.
基于IP地址的定位本质上是动态的，不会因eSIM而受到特定影响，但在eSIM环境下，定位工作的整体复杂性可能会导致执法部门更加依赖基于IP地址的识别，而这种识别方式本身也面临着动态分配和网络地址转换带来的挑战。.
配置文件切换与拦截连续性
One of the most significant challenges that eSIM creates for lawful interception is the potential for interception discontinuity during profile switches. When a target switches from one operator profile to another on the same device, the interception that was active on the first operator’s network must be coordinated with a new interception on the second operator’s network. In practice, law enforcement must identify the new operator, obtain a new order and serve it there, which may take hours or days, during which the target’s communications go unmonitored.
The speed and ease of profile switching in the eSIM model — which can be accomplished in seconds on many devices — contrasts sharply with the time required to establish a new interception on a different operator’s network. This temporal gap is an investigative challenge for law enforcement rather than a compliance gap for the original operator, whose obligation ends at its own subscription and the identifiers named in the order.
Addressing this challenge requires enhanced coordination mechanisms between operators and law enforcement, potentially including automated notifications when a target’s profile is deactivated and standardised procedures for rapidly establishing interceptions on the target’s new operator. Standardised solutions are not yet widely available.
多个人资料和多设备场景
eSIM技术能够实现传统拦截方法难以应对的场景。 一台设备可能同时承载多个运营商配置文件，这些配置文件可能来自不同国家的运营商。一名用户可能在多台设备（如智能手机、平板电脑、智能手表和笔记本电脑）上拥有eSIM配置文件。每种配置文件与设备的组合都会形成一个潜在的通信通道，可能需要进行拦截。.
For operators, this means that the scope of an interception may extend beyond the traditional single-subscriber, single-device model. Within its own customer base, the operator should be able to tell law enforcement which other subscriptions or eSIM profiles the same customer holds, so that the order can be extended. It can intercept only the identifiers the order names.
对于执法部门而言，多用户画像模型意味着一份截获令可能不够。如果目标对象在多家运营商的网络上都有用户画像，则可能需要向每家运营商分别签发截获令。协调这些多份截获令——以确保覆盖全面且无遗漏——增加了调查过程的复杂性。.
对LI系统的影响
To maintain effective lawful interception in an eSIM environment, operators must ensure that their LI systems address several specific requirements. First, operators should understand what the network actually sees. Switching profiles happens locally on the device. The operator’s network sees it the way it sees a phone being switched off: the target’s subscription deregisters, and the existing interception reports this as IRI. The SM-DP+ is not a real-time LI source. Its value is in the records it keeps, such as which EID a profile was downloaded to, which can support disclosure requests. The LI system should not push target data to the SM-DP+, which is often operated by a third party.
Second, the LI system must support the correlation of multiple identifiers associated with the same subscriber. A target may be known by different MSISDNs, IMSIs, and IP addresses depending on which profile is active. The LI system must maintain a mapping between these identifiers and the target’s interception order, ensuring that every identifier named in the order (MSISDN, IMSI/SUPI, IMEI/PEI) is intercepted, and that law enforcement can quickly learn which further identifiers the same customer uses.
Third, the LI system should deliver the standard registration and deregistration events promptly, since a profile switch shows up on the network as the target’s subscription deregistering. This information can be valuable to law enforcement in understanding the target’s behavior and in deciding on follow-up orders.
第四，运营商的 保单管理 system must be capable of handling the additional complexity introduced by eSIM. This includes the ability to modify interception parameters when the order is amended, to report promptly when a target’s subscription goes inactive, so that law enforcement can decide on follow-up orders, and to keep a complete audit trail of every order amendment, identifier change and task activation or deactivation.
监管与标准发展动态
LI standards address the issue indirectly: identifiers are always tied to the subscription or device, not to the SIM form factor. 3GPP’s 5G LI architecture (TS 33.127/33.128) is SIM-agnostic: it intercepts by SUPI, PEI and GPSI, whether the credentials sit on a physical SIM or an eSIM profile.
National LI rules generally do not treat eSIM separately. In Germany, the TKÜV and TR TKÜV are technology-neutral: interception is tied to identifiers such as MSISDN, IMSI/SUPI and IMEI/PEI, so it applies to eSIM subscriptions exactly as to physical SIMs.
结论
eSIM technology and the RSP architecture introduce significant new challenges for lawful interception, primarily related to target identification, interception continuity, and multi-profile scenarios. These challenges are not insurmountable, but they require operators to report registration events promptly, keep reliable records linking EID, ICCID and IMSI, and answer subscriber-data requests quickly. eSIM does not change an operator’s LI obligations; it changes how quickly law enforcement needs to learn about a target’s other subscriptions.
操作员的实用步骤
Operators should begin by assessing their current eSIM deployment and its impact on their existing LI capabilities. This assessment should identify any gaps in target identification, interception continuity, or multi-profile handling. Based on the assessment, operators should develop a roadmap for enhancing their LI systems to address eSIM-specific challenges, prioritising the highest-risk gaps first. Prompt delivery of registration and deregistration events, and the ability to answer subscriber-data requests from the operator’s own EID, ICCID and IMSI records, are the foundation for supporting law enforcement in an eSIM environment. Operators should also engage with their national regulatory authority to understand any specific guidance or requirements related to eSIM and LI compliance, and should participate in industry forums and standards development activities to help shape the emerging solutions.
随着eSIM应用的加速普及，eSIM合法截获方面的挑战将变得日益紧迫。运营商应在合规路线图中主动应对eSIM合法截获的相关要求。.
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