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The Communications Authority of Kenya (CA) has published draft procedural and technical safeguards governing the deactivation and recycling of inactive mobile numbers, opening a public participation window that runs until September 11, 2026. The notice, issued on September 1, 2026, sets out a multi-stage process that extends the runway before Safaricom, Airtel Kenya, and other licensed operators can reclaim a dormant line and reassign it to a new subscriber, while also imposing privacy safeguards on how recycled numbers are handled.
Under the draft framework, a mobile number will only be flagged for potential deactivation after it records no revenue-generating activity, defined as calls, SMS, data usage, airtime top-ups, or value-added services, for three consecutive months. Once flagged, the operator cannot proceed straight to deactivation. It must spend a further three months attempting to reach the subscriber through the contact details collected during Know Your Customer (KYC) registration. Combined, this brings the minimum dormancy period to roughly six months before a number can formally enter the recycling pipeline, unless the subscriber resumes revenue-generating activity in the interim.
"Number deactivation and recycling shall be triggered when a number records no revenue-generating activity, such as making/receiving a call, sending/receiving an SMS, using data, topping up airtime, or using the number for value-added services, for a period of 3 months," the draft guidelines state.
Why the CA Is Moving Now
The draft rules are not a routine regulatory update. They are a direct response to a High Court ruling issued on March 19, 2026, in which Justice Lawrence Mugambi found that a mobile phone number qualifies as an integral part of an individual's digital identity and is therefore entitled to constitutional protection. The judgment arose from a petition filed in June 2024 by Erastus Ngura Odhiambo, a prison inmate serving a 20-year sentence, whose mobile line was recycled and reassigned to another subscriber while he was incarcerated. The reassignment cut him off from family communication, mobile banking access, and other personal affairs without his knowledge or consent.
The court held that the risks illustrated by Odhiambo's case were not hypothetical. It ordered operators to stop reassigning deactivated numbers except under strict conditions: verifiable consent from the previous subscriber, or a public notice followed by a reasonable waiting period if the original owner cannot be located, coupled with technical barriers preventing a new subscriber from accessing the previous owner's linked personal data. The Attorney General was directed to work with the CA, the Office of the Data Protection Commissioner, the Kenya Prisons Service, and the relevant ministry to formulate a regulatory scheme within six months. Justice Mugambi set a hard deadline of midnight on September 19, 2026, warning that if no framework was in place by then, all reassignment and recycling of deactivated numbers would automatically and unconditionally stop.
That deadline explains the timing of the CA's draft. With a nine-day public comment window closing September 11 and the court's cutoff falling eight days later, the regulator has limited room to finalize the rules, incorporate stakeholder feedback, and publish a binding framework before the recycling freeze takes effect by default.
What the Draft Rules Require
The CA's proposed safeguards lay out a sequence operators must follow before a number can be recycled:
Initial flagging (3 months): A line is flagged for deactivation only after three consecutive months without revenue-generating activity.
Notification window (additional 3 months): Once flagged, the operator must attempt to contact the subscriber via SMS and any alternative contact details captured during KYC registration, rather than proceeding directly to deactivation.
Total dormancy threshold (~6 months): A number must remain dormant for approximately six months in total before recycling can formally proceed, unless the subscriber initiates activity that resets the clock.
Public notice (30 days prior): At least 30 days before deactivating flagged numbers, operators must publish the affected list on their websites, through other media channels, and in a nationally circulated newspaper. This disclosure must be repeated quarterly.
Self-check via *106#: Every notice must direct subscribers to the short code *106#, which allows them to verify whether their line is active, suspended, under recycling, or already deactivated.
Data scrubbing and privacy safeguards: Once a number is cleared for recycling, operators must securely archive and purge the previous subscriber's personal data, cached services, and financial linkages, so that a new subscriber assigned the recycled number cannot access the previous owner's accounts or private records.
The CA frames the exercise as a numbering-resource management issue as much as a consumer-protection one. "Given the finite nature of the numbering resources, deactivation and recycling of inactive and unused numbers is one of the practices in numbering, naming, addressing, and identification (NNAI) management. Globally, regulators are supposed to ensure that assigned numbers are prudently used before additional assignments can be issued," the regulator states in the draft.
The Numbering Squeeze Behind the Rules
Kenya's numbering plan is finite, and the CA has historically relied on a mix of prefix expansion and recycling to keep pace with demand. Since March 2026, ahead of the High Court's compliance deadline, Safaricom rolled out number masking for peer-to-peer M-Pesa transactions, hiding parts of the sender's number in SMS alerts, with plans to extend the same masking to merchant payments and bank transfers by the end of 2026. Operators have also leaned on the 0100, 0101, and 0102 prefix ranges to issue fresh numbers rather than navigate the legal complications now attached to recycling older, potentially rights-protected lines.
That approach buys time but does not resolve the underlying tension the CA's draft rules must now manage. A dormant line generates no revenue for an operator, yet the six-month minimum holding period, plus quarterly newspaper notices and a permanent USSD verification channel, adds recurring compliance costs to a resource that was previously reclaimed on a shorter and less structured timeline. Safaricom had experimented with paid dormancy-prevention products, such as its Daima line-retention service priced at KES 200 for six months, KES 500 for a year, and KES 1,000 for two years, though the legal footing of charging to preserve a constitutionally linked identifier is now less certain following the High Court's characterization of phone numbers as digital identity.
What Happens Next
Assuming the CA finalizes the framework within the court's window, telcos will need to update dormancy-monitoring systems to track the three-month and six-month thresholds, integrate the *106# self-check service, and build the newspaper and multi-channel notice cycle into their compliance calendars. The data-scrubbing requirement in particular will require operators to audit how personal data, cached app sessions, and financial linkages such as M-Pesa registrations are tied to a MSISDN, and to demonstrate that these are severed before a number re-enters circulation.
For subscribers, the practical effect is a longer and more visible process before a number can be lost to inactivity, with a defined self-service channel to check status rather than discovering a deactivation after the fact. Whether the CA can move from draft to binding regulation within the eight days separating the comment deadline and the court's compliance cutoff remains the immediate open question.
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