Grameenphone and Banglalink Seek Approval to Scrap Subscriber Forms

For more than seven and a half years, Bangladesh’s mobile operators have been storing all subscriber information digitally. Yet, they are still required to preserve physical Subscriber Acquisition Forms (SAFs), a regulation dating back nearly a quarter century. Despite maintaining Electronic Telecom Subscriber Acquisition Forms (eTSAFs) for every customer, operators face rising costs and security risks from storing millions of paper records.

Unable to bear this burden any longer, two leading mobile operators—Grameenphone and Banglalink—have formally appealed to the Bangladesh Telecommunication Regulatory Commission (BTRC) for permission to destroy their warehouses full of paper SAFs.

Banglalink’s Chief Corporate and Regulatory Affairs Officer Taimur Rahman explained: “We are maintaining an entire warehouse with hundreds of thousands of boxes of SAFs. But these paper copies are no longer necessary, as we already have digital versions prepared. That is why we have sought approval from the BTRC. If we receive the green signal, we will scrap them in compliance with regulations.”

Grameenphone voiced the same frustration. Imtiaz Shafiq, the operator’s Head of Regulatory Management and Commercial Affairs, said: “We have had to occupy space equivalent to a football field just to store customers’ SAF hardcopies. Although we already have scanned copies, we can only destroy the paper versions if the BTRC agrees. If approved, we will ensure proper recycling procedures are followed.”

The operators’ requests have already been taken under consideration. During its 298th meeting on August 25, the Commission discussed the matter and decided that further audits would be conducted before making a final decision. According to the minutes of the meeting on August 27, any destruction of paper forms must be carried out through certified recycling companies. Moreover, operators must preserve detailed lists of all destroyed SAFs and submit them to the BTRC. The Commission has also reserved the right to revoke or amend its approval at any time.

BTRC records show that Banglalink currently stores 29.37 million SAFs in its warehouses, while Grameenphone has 81.09 million. Together, the two companies want to destroy over 110 million paper forms.

Bangladesh’s four telecom operators collectively serve 188.8 million mobile subscribers. Grameenphone leads with 85.5 million users, followed by Banglalink with 57.5 million, Robi with 38 million, and state-run Teletalk with 6.6 million. Since September 30, 2010, BTRC has required operators to collect and preserve subscriber details—name, national ID number, date of birth, address, and fingerprint—on paper forms. However, from August 28, 2018, operators were also mandated to store all such information digitally in the eTSAF system.

Despite this shift, the ever-growing piles of paper forms have left Grameenphone and Banglalink struggling with spiraling storage costs and space constraints. Both operators now want to transition fully to paperless systems by discarding outdated hardcopies. Banglalink first filed its request to destroy SAFs on November 14 last year, followed later by Grameenphone.

According to available data, Banglalink holds forms for 71.07 million customers up to 2018, with 69.46 million already digitized. Of these, 9.57 million were flagged by the National Board of Revenue (NBR), while 212 forms are under legal dispute and another 519,257 remain under review. For this reason, the company seeks to scrap 29.37 million forms.

Grameenphone, meanwhile, has preserved 212.67 million physical SAFs, all of which have been digitized. Among them, all forms from 2005 to 2007 were flagged by the NBR. The company now seeks permission to destroy 81.09 million forms.