Strategies for system transition challenges 

At the strategy and design stage, Zambia must overcome several system risks: 

Technical risks

• Migration risks: the risk of transitioning from a legacy National Registration Card (NRC) system to a new digital ID system, while designing for a transition period where both systems need to run simultaneously.
• Infrastructure risks: risks related to phasing in and deploying the new digital ID system. This requires establishing infrastructure such as biometric registration kits for mass registration, constructing secure data centres and enhancing connectivity.
• Interoperability risks: the risk of interoperability problems and potential data protection concerns, given that multiple agencies are issuing their own IDs and collecting biometric data using different Automated Fingerprint Identification Systems (AFIS) and Automated Biometric Identification Systems (ABIS).
• Internet penetration risk: the risk posed by the lack of a supportive ecosystem of institutions that adopt inclusive approaches (including treating digital ID equally to physical ID), as Zambia only has a 56.8 percent internet penetration 
   

Operational risks

• Data safety and privacy: an increased risk of security breaches and inconsistent data management practices as biometric information is collected among multiple agencies for their own ID requirements.  

• Coordination: risks can arise as the county transitions to a unified digital ID system: this requires effective coordination among institutions and stakeholders implementing a legal ID system (Ministry of Home Affairs and Internal Security) and the Smart Zambia Institute (digitalization). 

• Digital ID coverage gap: risks may emerge when accelerating biometric enrollment of eligible citizens and providing them with a credential (digital ID). This requires enhancing outreach mechanisms with additional registration centres. Only 1.5 out of 9 million people have been enrolled with biometrics, although 89 percent have a paper-based National Registration Card. 

• Stakeholder commitment: there is the risk that only a few ecosystem players recognize the need for digital registration. As understanding grows, so does the commitment to deploying a national digital ID.

• Training requirements: the risk of a lack of capacity; training staff in over 145 offices across 10 provinces on the Data Protection Act requires added capacity and coordination. 
   

Normative risks

• Legal framework: risks could arise when updating the National Registration Act, Citizenship Act, and other key regulations, although this will further align Zambia’s identity system with modern digital standards and promote inclusivity and legal clarity.  

• Harmonizing data: there are risks around inadequate training; harmonizing data across various acts and institutions requires appropriate training for personnel handling personal data and greater public awareness about data protection rights and practices. 

• Refugee and asylum-seeker inclusion: there is a risk of impacting marginalized groups; Zambia hosts over 105,000 refugees, asylum-seekers, and other persons of concern. With mass registration efforts paused, coverage and access to basic services for these individuals may be impacted, risking exclusion if integration and collaboration with UNHCR data are not prioritized.