Article 40(a) and (b) further criminalise the provision of services to unregistered SIM cards or to lines making an “unusually high” number of daily calls, punishable by up to seven years’ imprisonment, while Article 34 imposes up to three years’ imprisonment for registering a SIM card with incorrect details. These provisions directly target the secure and unregistered channels relied upon by underground activists and civil resistance networks. Compelled disclosure without judicial authorisation, backed by criminal penalties, further entrenches arbitrary surveillance and coercive private-sector participation in rights abuse. International legal assessment This framework cannot be justified as an ordinary or proportionate response to online fraud. Under international law, any interference with privacy must be lawful, non-arbitrary, necessary, and proportionate (ICCPR, Article 17). Even where States pursue legitimate aims such as fraud prevention or cybercrime enforcement, surveillance measures must be narrowly tailored, subject to independent oversight, and limited to what is strictly necessary in the individual case. The Bill does the opposite. Rather than authorising targeted measures based on objective grounds, it constructs a standing architecture of indiscriminate access, centralised monitoring, and compelled disclosure across the banking, telecommunications, and internet sectors. It dispenses with judicial authorisation and vests sweeping powers in a militarised Central Committee (Article 5), dominated by the Ministry of Home Affairs and its security apparatus. In that context, the Bill is not a neutral regulatory response to digital crime. It is a legal and technical framework for repression, designed to convert anti-fraud governance into a system of mass surveillance capable of identifying, tracing, and punishing those who rely on digital tools to organise, communicate, and resist military rule. Silencing digital dissent through “false” information offences The military regime routinely invokes anti-cybercrime justifications to suppress freedom of expression, including independent journalism, digital activism, human rights documentation, and online efforts to challenge the regime’s authority. This Bill further codifies those practices by criminalising vaguely defined speech, expanding censorship powers, and extending repression beyond Myanmar’s borders. Criminalisation of allegedly “false” information Article 31 prohibits distributing or transmitting “false” information over a communication network for the purpose of committing fraud. In Myanmar’s highly contested information environment, however, the military regime reserves the power to determine what is true or false. In practice, this enables the regime to characterise reporting on military atrocities, civil resistance activity, or online humanitarian coordination as “fraudulent” or deceptive.

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