GSMA RSP (Remote SIM Provisioning) specifications require TCP/IP stack and, in case of M2M, the support of SMS protocol for remote communication with eSIM-capable devices. However, network constrained devices (e.g. 3GPP devices supporting NB-IoT or non-3GPP devices) either don't support these protocols or are limited in the performance (e.g. due to high latency). Therefore it is either very troublesome or simply impossible to implement eSIM management strictly compliant with GSMA RSP specifications.
In some cases SMS-over-IMS can be seen as the solution for remote switching between pre-installed mobile network subscriptions in the B2B IoT devices. Some other IoT devices could be provisioned using modifications of the existing RSP standards. For example, an B2C IoT device that is procured by a human user for installation in the home environment (like surveillance camera or temperature sensor). It could be managed as a companion device of mobile phone or tablet of this human user in accordance with GSMA SGP.22. But this is not suitable for the unattended UI- and network-constrained devices, such as sensors, which make up the largest share of IoT devices, requiring new approaches for eSIM adoption.
A certain combination of IoT device firmware and a remote entity managing the subscription states in the IoT device is required to successfully manage eSIM in such constrained devices. This remote entity shall include capability to manage subscription states remotely (activate, deactivate and delete select profiles) and to assist the device in discovery of the respective SM-DP+, from where the mobile network operator subscription can be downloaded. This remote entity may be seen as an evolution of SM-SR defined in SGP.02 but without its complexity in regards to the integration with eSIMs and other entities of the ecosystem.
The complexity of the M2M architecture defined in SGP.02 has become a major showstopper for mass deployment of eSIM in IoT devices. It's being used by some global players to block competition by creating high entry barriers for newcomers and ultimately risks the failure of eSIM technology in IoT.
It is more than exciting that key industry players take the initiative to create an open ecosystem using the consumer RSP (SGP.22) as a basis for the IoT application segment. If the industry manages to create an open and fair standard addressing the various use cases and deployment scenarios for constrained IoT devices with eSIM, it will create a major push for the mass adoption of eSIM in the entire IoT space.