1. Regulatory focus
On 30 June 2026, the CRTC opened Telecom Notice of Consultation 2026-155 and directed Bell, TELUS, and Rogers to show why certain charges should not be treated as unlawful barriers to switching. The most relevant point for cross-border connectivity teams is TELUS’s C$15 charge for both physical SIMs and digital eSIMs. CRTC staff had already signaled that a SIM or eSIM is required to deliver wireless service and therefore may not qualify for the optional-service exemption. That places the charge close to the prohibited activation-fee category under section 27.04 of the Telecommunications Act. The prohibition has applied since 12 June 2026, with carrier submissions due by 30 July 2026.
2. Business impact
The impact is operational, not theoretical, for businesses that use Canadian mobile numbers for login, OTP, billing alerts, customer callbacks, and continuity messaging. If regulators treat SIM, eSIM, device setup, and shipping charges as potential switching barriers, carriers and downstream partners will need to revisit pricing tables, checkout logic, disclosures, care scripts, and reseller messaging. This is especially material for SaaS, fintech, and travel-connectivity providers that position eSIM as a low-friction activation path. Poor fee treatment can create more than complaints and churn: it can also create Wireless Code exposure and administrative penalty risk, with first-time corporate violations potentially reaching C$10 million.
3. Operating recommendations
A practical response is to separate Canadian eSIM charging into three governed buckets: required fees, optional fees, and replacement or recovery fees. Any SIM or eSIM amount that appears in a new activation, plan change, switching, or device migration flow should be reviewed against the activation-or-modification fee standard, not just local commercial policy. Teams should also audit web checkout, API price fields, partner-reseller terms, agent scripts, and refund logic so that a required service component is not presented as an elective add-on. If OTP is part of the onboarding fallback, add non-SIM contingencies such as email verification, passkeys, or in-app step-up verification to reduce conversion loss during activation disputes or delays.